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'0 ~ -" c-oSS ~ 0<, 0 ] "'" "" " " '" '", 5), c 8 2- 0 ;; ~ f; , ~ '" : " c F <; 1 PUBLIC HEALTH THEN AND NOW [j(aminiflg PI-PVIQusly undel-used corporate documents, we revisit the story of the Asbestos InFormi1r!on Associarlon/I"-Jorth America, an industry trade group that 50ughr In the early 1970s to : Olmreract tile growif'g public attention to, and government regulation of, asbestos as a serious t h,-eaL to workers and consumers, From the mid-1960s through the early 1970s, according to its uvvr, spokesperson, asbestos was exposed as "pmbably the most hazardous Industrial material ever C!nleashed on an l!nsuspccling world" in relrospect, thousands of lives may have been saved f the Asbestos !nformction Association had publicly acknowledged this earlier, (Am J Public Health publi:)hed onllline ahead elf print Febl-uary 18,2016, e1-e7 dOI'1 021 05/AJPH 2015,303023) "My answer to the problem is: if you have enjoyed a good life while working with asbestos products why not die from it. There's got to be some cause." -EA, Mart"', Bendix COIporatlOn, (0 Noel Hetn/dry. Cmadian Johns-Matwille Caorp, 1966,1 III the nlldclle decades of the 20th century, asbestos, d f1uner.l! with insulatmg and tire-resistant properties, was Widely dlstnbuted throughout the Amencan ldnd,cape. A matenal used for a very lmlited number of purposes in the 19th century, by the 1960s It WdS used in thousands of household and industnal products, includlIlg floor tiles, paUlts, roofing materials, caulks, plastics, and even Chnstmas tree "snoW:'2 There IS a very nch literature on the history of the asbestos lIldmtry. Various scholars have documented what the industry did to hide lIlformation and therefore delay dction that might lead to restrictIOns on Its lIse. o In short, these authors have illustrated that, as with the tobacco and lead lIldustnes, the dangers of asbestos and its speCIfic relationship to cancer were extenSIvely reported on in the medical hter,lture but minimized and eVen hidden by variOllS compallles and indiViduals. We focm on the early 1970~, specrtlcally the Asbestos InformatIOn AssoCliation/North J\menca (J\IJ\/NJ\) , an industry trade group that had mternatiOolmUl ties to dnd worked in tandem With the "British Asbestos Information Committee and AsbestOSIs Research Council, and smular groups in France, the Benelux countrIes, and Scandanavia."4 Established III December 1970, the same month that the OSH Act was Signed mto law, ItS goal was to counteract the growmg public attentIOn to and government regulation of asbestos as a serious threat to workers and consumers.We analyze how the industry sought to shape public opilllon and regulatory polilcey. The AlA cla1ll1ed that as a result of Its efforts, the OccupatIOnal Safety and Health Admmistration (OSHA) regulatIiOons adopted in 1972 mcorporated most of their suggestions, espeCially that asbestos could continue to be used in a wide vanety of consumer products without any warlllngs about the cdlaannger of cancer.5 This was despite a nch hlStoncal lIterature on asbestOSIS, lung cancer, and mesothelioma dating to early m the 20th century.6 The AlA was born ofJohnsManville's public relatIons efforts. In October 1970, the Public Relations Subconuruttee of Johns-Manville's EnVIronmental Health Task Force had a meeting with representatives from Hill & Knowlton, a public relations firm, to discuss the formatIion of an organization to address the growing attentIOn to the health effects ofasbestos products they feared could lead to a ban. Therefore, from its formatIion the AlA was a creature of industry and of the Hill & Knowlton publIc relations firm, now infamous for developing strategIes to counteract challenges to a varIety of pollutmg mdustries, IIlcludmg tobacco, lead paint, and asbestos'" Matthew Swetonic, a graduate of the Columbia School ofJournalism whose initial Job was in the publIc relations department of Johns-Manville III the 1960s, became the fir~t executive secretary oftheAIA.8 He related the AlA's transformation trQm an "information" orgalllzatlOn to a defender of asbestos: [n our ongmal concept the As,oclatlOn would ~rrut Its actIVItIes to provldlng accurate, unbIased mformatlOn on asbestos and health to the press. the pubhc and to mterested polhItliCIlans and other government offiCIals . [But] fortunatelY-<lnd properly-the fusoClatIon has had the Wl:>dom to alter It> onglnal hnuted concept of Its proper functIOns, and now endeavors to assume whatever aCtIVItIes and respon- published onlline ahead of print February 18, 2016 AJPH M/VaIarkrkOoWwlitz and Rosner Peer ReVIewed Public Health Then and Now e2 PUBLIC HEALTH THEN AND NOW slbJhtles It deems neces~ to protect the lnterests of the asbestos manufactunng mdustry In the Umted States vIs-a-vIs asbestos-health 9 WIthin months of its formatIon, the AlA had made the shift. One of the first tests of its true rrussion came in early May 1971, when the International Ladies Garment Workers Union held a news conference with Dr. Irving Sehkoff, the nation's foremost expert on asbestos-related dISeases, to call attentIOn to the fact that asbestos was used in certain lllported women's coats, potentially creating dangerous consmner exposures. At the conference, Selikoff was asked "what a consumer should do If she discovered she owned such a coat;' to which he rer.;lied, 'bury it."'IO Sehkoff went to the AlA with a specific request that, as an mformatlOn service, the AlA should pubhcally"condemn the use of asbestos" in the coats. However, Swetonic told the AlA's board of drrectors, To condemn the use of the cloth on the baSIS of Its bemg a health hazard would place the AIA/NA In the posltJon of glvmg tacit approval to the contentIOn that even shght exposure to asbestos can be hazardom. [whIch would] completely undercut our current efforts to defeat local, state, and federal moves to ban asbestos-contalDlng products. IllI The AlA dId not take a public stand, reallZmg that it could not both provide "accurate 'informatIOn" and, as an Instrmnent of this mdustry, defend its interests. It had to choose. And It did. The activities of the AlA were generally defensive. By October 1971, the AlA's public relatlOllS can1paign provided its VISIOn ofthe health hazards of asbestos. In a pamphlet titled "Asbestos and Health: QuestIOns & Answers;' the AlA asked, "Can a lIttle, bit ofasbestos kill you?" to wluch It responded, "Long term medical studies of occupationally exposed workers show that low to moderate levels of exposure to asbestos do not lead to an increased rate of disease:'12 This was despite the vast lIterature that had accumulated since the early 20th century that indicated the opposite. As early as the 1930s, researchers documented that asbestos dust produced asbestosis even at concentratlOllS invlSlble to the naked eye. With the recognItIOn of the relatIOnshIp ofasbestos to cancer it became dear that vrrtually any occupatIOnal exposure might cause disease and death.13 The AlA pamphlet also posed the question, "To what extent IS asbestos an occupatIOnal health hazatd?"The AlA acknowledged that asbestos-related diseases were not a recent'discovery; they dated back at least'to 1930. 14 But, it argued, those diseases did not reflect the kinds of conditiOn> that workers faced m the 1970s and were a product ofpractices that had long been abandoned or lllproved, "when the dust control equipment in use was not as efficient or as sophistIccaatteedd..""!lSs This was a disingenuous interpretatIOn of the histOrIcal knowledge .of the dangers of asbestos. Smce the 1930s clinicians had been discoverIng lung cancers in workers exposed to asbestos.l1o0 By the 1950s, major surveys and an epidemiological study by Srr Richard Doll confirmed the observations of chnicians, pathologISts, and radiologists worldwide who had documented lung cancer in asbestos workers.!7 Along with these observations went a critique of the relatIOnshIp between the amount of exposure and the safety of asbestos. Henry Smyth, who was research drIrfector at the Mellon Institute and a long-time employee of Umon Carbide, wrote that cancer made the older threshold limIt values almost rrrelevant,"At this tmle it IS prudent to set the ,tandard for a carcll10geruc substance substantially at zero."18 Irvlllg Sebkoffsuccmctly pulled together the emc'rging consensus about the melevance of the threshold lrrnit value as a measure of safety when speakmg of asbestos and cancer m his ClasSIC 1964 article in the jO/Jrr/al of the /jmencan Medical AssociatIOn l'Asbestos Exposure and NeoplasJa.""Build1l1g trades Insulation workers have relatively bght, intermittent, exposure to olsbestos," he noted. And yet these workers had very elevated rat~ of asbestosIS, lung cancer, and mesothelIoma.19 In 1971 OSHA issued anno, "emergency standard" for exposure to asbestos dust of 12 fibers per cubic centmleter, wluch was dramatically lower than the level of exposure first established by the Arnencan Conference of Governmental Industrial HygIenists m 1946 offive millIOn particleS per cubIC foot (roughly equivalent to 30 fibers per ecc). In 1972 the NatIOnal Institute for Occupational Satety and Health (NIOSH) proposed to Significantly reduce the permisSible exposure l~t to two fibers per cubic centimeter for protection against asbestom, acknowledging that there was "lI1suffiClent informatIOn to establISh .1 standard to prevent ... asbestos mduced neoplasms by any allmclusive lrrnit other than one of zero." 20 This proposed regulqtion was perceived as a drIrfe threat to the asbestos mdustry and led the AlA to appeal to OSHA for restrall1t. The Immediate problem, the mdustry argued, was that "past experIence" proved that tor e3 Public Health Then and Now Peer ReViewed MaarrkkOaWwlitz and Rosner AJPH Published onliline ahead of Pllnt February 18, 2016 PUBLIC HEALTH THEN AND NOW "a sizable number of operations It will be unposslble to reduce the levels to two fibers, no matter how much money is ,pent," and III light of the uncertalillty of what constituted safety, It would be unfarr to adopt an unworkable standard. "The simple truth IS that no one, NIOSH mcluded, knows for sure what a safe occupatIOnal standard should be."21 NIOSH and OSHA sought to place greater and greater lunit> on asbe,tos exposures. The goverrunent argued that because of the lack of knowledge about what level of exposure could be safely tolerated, prudent public health practice demanded precautIOn m the form oflowered exposures.The AlA took that :lrgLUnent and turned it on Its head: because no populations have been consistently exposed at the levels NIOSH had suggested and because there were no studies that "would suggest an excess of malignant tLUnors among persons exposed to no more than 2 asbestos fibers per cc of air. .. ," there was no scientific justificatlOn for settlllg levels so low.2' As a political agency, OSHA adopted a pragmatic appro.lch, setting the limit at five fibers per CUbIC centimeter in 1972 to be reduced to two fibers per cubic centl.l11eter in 1976, glvmg the Illdustry four years to reduce exposure to NIOSH's recommendatIOn. OSHA ,tated that thIS would reduce the mm1ber of cancers while not necessanly elimlllating all ofthem. 23 The AlA also objected to the recommendation by the OSHA AdVISOry Committee that the w,lmflnng label include the word "cancer" because such d label would ,sppell the defw::,e of Ilurnerous ITL1Jor product hnes of the lndustry, Indud- mg v1I1yl asbestos floor Ille. asbestos pIpe, and any other product that IS sold chrectly to the consumer market. .. .0' This objection was derived from the industry's contention that such a warning was not necessary because "the IHlllajjoorrity of asbestos-contatning products ... [wereJlocked m," that is, bonded with various resins and other stable matenals.25 A few montru later, Swetomc privately acknowledged the lirruts oflus publically stated pOSItion. Using the exan1ple of cement pipe with asbestos embedded m It, he described ilie very problem that had been Identified histoncally. "The field cutting or trirmnnunng of asbestos-cement pipe, Ir1mllgght produce levels in excess of the statldard, but only for the man doing the actual cutting and only mterI111ttentiy or rarely:' But he opposed placing a warnmg on such asbestos-contaming products because it would "alarm all those handlmg the product, when only one man has a potential excess exposure."26 In June 1973, less than a year after Swetoruc had written to member companies about labeling asbestos products, he gave an address to the Asbestos Textile Institute, an older, more narrowly focused asbestos trade as- sOClation. In this private address, Swetoruc said, "The medical literature IS full of solid evidence linking asbestos to dISease," citmg"more than 2,000 medical articles dealing with the health nsks ofasbestos."27 These were prunarily aimed at the medical and professional communities, but he observed, "Starting with Paul Brodeur's infamous New lorker article of March, 1968, asbestos has' since grown into an The JM Jeffrey Asbestos Mine, Asbestos, Quebec. Note The Town IS positioned around th" rim of the Pit, which measures about 1 mile In length and 1200 feet deep Most of the asbestos sold from thiS mine was being exported to third world countries. In 1988 the mine operated 364 days, on a double shift. ThiS was the largest chrysotlle asbestos mine In the western world. Source Photo by Bill Ravanesl, producer of the documentary exhibition, "Breath Taken. The Landscape & Biography of Asbestos" Printed With permiSSion PublIShed online ahead of prlnt,February 18, 2016 AJPH MarrkkOoWwlitz and Rosner Peer ReVIewed Public Health Then and Now e4 PUBLIC HEALTH THEN AND NOW item of major pres, interest."JS As a result, pubhc relatIOns was now "the single largest consumer of time, effort and money.wlthin the Association." This publicity was overwhelmmgly negative, and the AlA had done all it could "to present the press wIth a balanced view of the asbestos-health SltUation."'9 He told the audIence that the AlA had prepared and prInted an Asbestos and Health Information File, "whIch we have mailed to some 3,000 newspaper" magazmes, trade publIcatIOns, radIO and TV statIOns, science writers, etec. across the United States.")O In addItion, the AlA had disseminated "timely, constructive news releases and artIcles" and prepared "carefully selected responses to editors as a result of'damaging, irresponsible stories."'l' But now a new approach was needed. Accordmg to Swetoruc, "The pres, relatIOns battle will ... be 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."32 IrOnIcally, the Asbestos Information Association saw as its new goal the exact opposite. From Swetonic's viewpoint not all was lost, despite the spate of negative publiCIty about asbestos.As he told the ATI, "HaVIng [heard] the bad Side of the public relatIOns problem, It'S tlUle for some good news." "The good news IS that despite all the negative articles on asbestoshealth that have appeared m the press over the past half dozen years, very few people have been paymg attentlOn."The AlA hIred a prestigious public relations firm that mterviewed "more than 2,000 demographically selected Americans," reporting that"only 22% of the Ameennc,an public are aware of the health hazard~ of asbestos." Of these, 80% considered It "a hazard only to those who are occupatIOnally exposed;' a result that he thought "should be reassunng.")} Swetoruc understood the irony of what he was saying. Here was aq information service that was celebrating that the public was not understanding the inforUJation that was being publically reported. As Swetoruc told the AlA board of rurectors six months later, the results of their survey "show that the average man has httle concern with or awareness of the health problems being assocIated with asbestos."34 Although the mdustry took solace Ul the publIc's lack of understanding, they worned that federal regulators might act anyway. The AlA feared that even though OSHA's perUllSsible exposure limit was about to be reduced to two fibers per cubic centlmeter in 1976, there would be continuing pressure to reduce it further, a fear confirmed when NIOSH proposed such a reductIOn to 0.5 fibers per cubic centlmeter In 1975 and then 0.1 fibers per cubic centlUleter m 1976, then conSIdered the lowest detectable leve!.35 Guy G. GabrielsonJr, the vICe-preSIdent of the AlA, reported to his membership the position OSHA officials had taken at an AlA-sponsored Industry-Government Conference m September 1976. OSHA "seem~ to say that there is no threshold;' he told hIS members. "You get to zero fISk at zero exposure, and in the case ofall diseases that will occur during a workIng lifetime." He reported that the OSHA official "seemed to say ... that the only way we can be sure that there is no risk ofdisease is to ban asbestos." This was a position that was the same as NIOSH's recommendation in1972, when they argued, "To prevent such dISeases mcluding asbestos-mduced neoplasms" only a level of exposure approachmg zero could truly be protective.'o In 1976, NIOSH went further, confirmmg th~ assoCIatIOn's fears, asserting that when considering cancers, "only a ban can assure protectlOll agaulSt effects of asbestos."" Gabnelson made dear that this was untenable for the asbestos mdustry: "We can't go to zero risk." Rather, the industry had to reject OSHA's and NIOSH's position by argumg that the "two fiber level IS sufficient to protect our work force dunng a workmg lifetime," although he "adtrut[ed]" that they could not "prove that, partICularly m the case of mesothelIoma."38 At every stage of the standard-settmg process, the AlA fought a rearguard actIon to limit the burden any regulatIOn might place on them, espeCIally an effective ban on asbestos exposure. Swetoruc clalUled credIt for getting OSHA in 1972 to accept most ofAlA's recommendations, argulllg that Its success was "a gauge of the effectiveness of the totalmdustry mvolvement in this most crucIal matttteer.r".3"9" He pointed out that there were 11 ~crr parts to the OSHA standard, and of these, "the industry pOSItIon wa; accepted totally by OSHA on rune of the eleven, about 50 per cent 011 a tenth, and totally rejected on only one." In 1976, Gabnelson outlined a program to forestall government actIOn to reduce the permissIble exposure limit: I have recommended to the ExecutIve Cornrruttee of the AIA/NA thalt we use every tool m our command to make our pOlnt WIth the regulatoryauthOrItIes, that we exhaust our adrrumstratlVe remedles, and If at that pOomint we stIll eS Public Health Then and Now Peer ReViewed tMvalarrkkOoWwlitz and Rosner AJPH Published onilline ahead of print February 18, 2016 PUBLIC HEALTH THEN AND NOW do not have the kllld of standclrd we dlln k we reqUIre to run our bUSInesses that '\vce go "head and go to court to c1dlenge an unsatlsfactory regulation. I beheve the system perrruts us to do thIs and we can do that Wl th a clear consnence 40 The mdustry believed it was under assault not only from government regulators but also from the courts, where dISeased workers were beginnmg to brmg hability SLlltS. In 1971 the Borel !( h berborlrd :1 rtlcele Produds CorporatlOIl deCISIOn provided the basis for thousands ofliability lawsuits agamst asbestos manufacturers, sllch as Johns-Manville, Raybestos, ,md compallles that made products out of asbestos. By 1976, the effects of these lawsLllts were havmg a dramatic inlpact on the mdustry. The AlA noted "problems confronting the mdustry 1ll regard to cancellation of product lublhty insurance coverage, increases m product hablhty Insurance premlUrns and higher deductible features." At its board of drirectors' meetmg m December 1976, Vice-President Gabnelson feared [hat some cu~torners of AssOCJatwo nlcrnbers VIew the product lldbl1Jry problem as. all Incllcatlon that an Imparbol Judge. 1.e. the msurance (omparue::" has ceO01Ine to the cOllcluSIon that asbestos 15 a more hazardous matenal than I11dustry has told them 41 Iflt was to surVvive, the mdustry had to deVelop a coordmated legal, pubhc relatIOns, and medical program to counter the growlllg threat. They hrired Phtlhp Enterline, then charir of the Biostatistics Department at the UlIlilversilty of Pittsburgh, to wnte a state of the art review of the lIterature on asbestos and dIsease to prepare for cOorlrnng IaWSlIlts. They also began to lIltervlew "physICians around the country who nllght qualifY as expert witnesses m 3rd party litlgation."42 They also began to rure researchers to "prove" that the mam threat came from crocldolite, "blue asbestos," and amosite, not chrysotrle, the mainstay of the Amencan asbestos industry.'3 In the succeeding decades the asbestos industry devoted huge resources to recruiting scientific experts, lawyers, and medical personnel to fight the lawsuits brought by thousands c.f victims of their "magic mineral." In addition, from the 1980s through at least the first decade of the 21st century the AlA cont1l1ued its rearguard action to fight warning labels on asbestos products, oppose a ban on the uses of asbestos, and 111 general defend the 1l1terests of the mdustry. 44 Workers and family members dy1l1g from asbestosis, lung cancer, and mesothelioma would drive major corporations like Johns-Manville into bankruptcy. At the same time that Vlct1rllS were holdmg compaImlles accountable, OSHA was promulgating new, lower and lower standards (the pernusslb1e exposure limtt was reduced to 0.2 fibers per cubiC centimeter in 1986 and, 111 1994, two decades after NI06H first proposed it, a 0.1 fibers per cubic centimeter permissible exposure limtt). Natrional and international organizatIons such as the InternatIOnal Agency for Research on Cancer, the International Labour Organization, the World Health Organization, and NIOSH concluded that all forlllS of asbestos were human carcl11ogens. Despite the most fervent efforts of the mdustry to protect itself from lawsuits, the asbestos industry became nearly as notorious as the tobacco industry in the pubhc mind. Matthew Swetonic, the first executive director of the AlA, who later worked for the tobacco industry as he had for asbestos manufacturers, declared the "death of the asbestos industry" in the 1990s. "What happened?" he rhetorically asked. "What drove that once nughty industry 1l1to the dust? It's srrnple:' he Ssaariddo. "During a relatively short period of tlme from the mid1960s through the early 1970s, the 'magiC mineral' was exposed for what It really was-probably the most hazardous industrial material ever unleashed on an unsuspecting world." Swetonic spoke With ~ardonic authorIty:"I know. I was there:'45 In retrospect, thousands oflives may have been.saved ifhe, and the Asbestos InformatIOn Association, had Ssaarid this earlier. AJpI-I ABOUT THE AUTHORS CGeroaild MarrkkOoWwlitz is with the Depallmetlt oj Inte/dlSdplmary Studdiieess,,john Jay Col/ege, New York, NY; the PhD Programs in History and Public Health, Graduate Center, CIty University of New York, New York; and the Department of Sodomedical Sdences, MaIlman School ifPublic Health, Columbia University, Neu; York, N):-' David RROosS''lleer 15 WIth the Department ofSOCIOmedIcal SCIences, Mailman School ojf Public Health, Depart ment ofHIStory, and Centerfor the HIStory and Ethics of Public Health, Columbia Unit'ersily Correspondence should be sent to Gerald Markowitz, PhD,john jay College, 524l#st 59th Street, Room 6 65 06, New York, NY 10019 (emad gmarkowitz@J;ay.Clmyedu). Reprint, can be ordered at httpllwww.ajph O1g by clicking ihe uRepntlts" lmk TItis article was accepted November 27) 2015 doi.1O.21OflAjPH 2015.303023 CONTRIBUT-QRS The authors contnbuted equally to the research, wn~mg, and conceptuahzatlOn of thIS article. ACKNOWLEDGMENTS The authors would lIke to acknowledge that many of the pnmary source documents were gathered In the process ofhtlg>tIon reg,rdmg ",bestos-related dIisease~. These documents are avadable onlme at http.!/wwwtoxlcdocs org, a Web SIte ofcorporate memos, letters, reports, and other papers developed through the cooperative efforts 01 the Center for the HIstory and EthICS ot Pubhc Health, ColumbIa UIllversIty, City Umverslry of New York; and the Center for Public IntegntyThe authors have appeared ~ expert WItnesses on behalf of plamttffs m asbestos law~Ults ENDNOTES 1 E. A Martlll. BendIX to Noel Hendry. Canachan John,-ManvIille Corporation, September 12.1966 2 See E R. A Merew<;ther and C W Pnce, Report OHll Effects of Asbestos DIuI,t on the Lungs ana Dust Suppressio,1 ItI the Asbestos Industry (London, UK Her Majesty's StatIOnary Office. 1930) fOl a dIscLlssIOn of the growmg uses of asbestos In the 1930s. 3 See, e.g., Balry I Castleman and Stephen L Berger, Asbeslos' Medical and Leg,,1 Aspects. 5th cd (Englewood ChtE. NJ PrentICe Hall Law and Busmess. 1993), Paul Brodeur, Outrageous .MI.SCotlduct. The AsbeSlos 1I1dustry on Tnal (New York, NY Pantheon Books, 1985). Jock McCulloch. Asbesto, Its Humall Costs (CSSt LUucClIaa, AustralIa UnIVerSIty of Queensland Pless. 1986),Jock McCulloch. Asbesto, Blues' L1lbboollr, C"pttul, Physicla1ls atld the State hi South Afoca (Bloommgton, IN' Indiana UnIversltv Press. 2002). Gceoffrey Tweedale. MagIC Minerali to Killer Dust Turner & N,walil and tire AS,besto; Hazard (Oxford, UK. Oxford Ullliverslity Press, 2000). DaVvlid Egllman, "Dust DIseases and the Legacy of Corporate MalllipulatlOn of SCience and Law." Intmutionaljoltmal of 0;. cupatlOHal and EtlvlYonmentdi Health 20, ,I. no 2 (2014): 115-125 Jock McCulloch and Geoffrey Tweedale's. Defending Indeji"'S1ble' TIle Global Asbestos Industry and It; FlJiht!or Suw",ivai (Oxford. UK Oxford Ul1lVerslty Press. 2008) prOVides an Important per~peCtIve ()n the asbestm story, mcludmg the pomt that the Asbestos InformatIOn ASSOCIatIOn wa~ part of an lllternatlOnal effort to defend "the mdefenslble " 4 Asbestos InfonnatlOn As:>oclatlOI1, The Asbestos InformatIon ASSOCIatIOn/North Amenca (W",hmgton, DC. ca 1972). 3 5 Asbestos InfonnatJOn A~SoClatlOn, Chart companng OSHA. NatIOnallnstltute for OccupatIOnal Safety and Health. and mdustry-suggested regulatlOns, attached to Swetofllc to AIA/NA Member Compallles. June 12. 1972 ThiS study IS based upon an eXJl1lIllatlQn of prevlOu~ly underused ecorrppaannte documents now avaIlable through the dIscovery proce:>"S of laWSUIts aga.tnst the asbestoos, mdustry These documents are pubhcally avaIlable on the Web sIte http / /www toxIlcdoc<; org, sponsored by the ColumbIa. Umvt'Tslty Center for the History and Ethlcs of Public Health, Gnduate Center of the CIty UnIVersIty of New York, and the Center for Public Integnty. published onlline eheed of print February 18, 2016 AJPH Markowttz and Rosner Peer ReVlewed Public Health Then and Now e6