Document R23Ge6YJK61E8Y1dZyEbxOQEB

`Wi-.iu ->-- IT<->UOL, *0 V ./*<; iMr L - / 4 l/ day 1' synthetic (uL acd still have enough The sleeping giant 'hat u the American cardsogcnle la human* or in two or mors fo-xll years* wot. when onee scoured, trlump Just as animal testa--essentially the Delaney Clause B> then, we mar be geting most of our gloriously over our present crisis x ask you requirement to the 3 OSS Food and Drug cicrjy Iron solar power. to help ms to awaken him.* Oat--would immediate]r be clamped turner TKI NJ3IO Or COM> tigne oontrei in Cstegory 1. Worker expo Tberr ii nothing new la the Idee of Disking lioui had tuela from coal, until the statu...; pa~ pipeline wee built In the 1040's, practically ell the gw that trtts urvd on the Em: Cu*.st--~*nd as far vwt aa El Louis-- carat frem coal. Tlie Gvmr.ns, cut off from otl 1b World War II ran their war machine on gasoline made fMr. BRADQ1AS asked and was given permission to extend his remarks at this point in the Record and to in clude extraneous matter.) [Ur. BRADEMAS' remarks uni appear hereafter in the Extensions of Remarks.) sure* would he limited to the lowest possible level*, ena medical surveuiance and exposure teats would be required. Suosubce* would be lumped Into this Categsry 1. on tn emergency basis, without any attempt to interpret or analyte the queltty of the research concluding the substance la carcinogenic. Presumably, these substances from coal. Aad a formidable thing It wu. As early m 19S3. tb Paley Commission warned us that we ware running out of oil and gas and that we'd need a synthetic fuels OSHA: CANCER AND THE POLITICS OP PEAR eould later be given individual review and found innocent; until then, they are to be presumed guilty, and barred. Substance* for which evidence of earclno- ludusir). South Africa already Is convertlag eoal to oil and gas. They've invested more than SI billion in the proeoss. Aa a percentage of lhair total Income, that would compare with a **4 billion Investment on our part. (Mr. HANSEN asked and was given permission to extend his remarks at this point in the Record and to include ex traneous matter.) Mr. HANSEN. Mr. Speaker, Z have gsaieity 1* merely "suggestive" would go in;o Category 2. medical surveillance and exptsurv monitoring would be required, but any existing exposure limit would not hart to be revised to ea Immediately lower level. Those substances which show bo evidence of According to calculation* In the Depart* been informed that in the very near fu being carcinogenic would go into Category merit of Enervy. a ctven dollar investment Ln cool liquefaction will produce approximately four time* the payoff la energy volume as an equivalent dollar Investment la a nuclear plant. Tor IS years we have been building pilot plants on a penny-ante budget. We haven't built commercial plants be cause the necessary investment li too massive to be undertaken by private Investors with out clear assurance that the government will stand behind them. It cost perhaps (li blUloo to build a plant which could produce a high grade synthetic oil which could be sold for something like *3$ a barrel. Who Is going to Invest that kind of money without some assurance that It wouldn't be a total lost if the Arabs, who control the surfer;, should suddenly cut their prices back to. say $15 a barrel?. The government, therefore, must make a decision--s* we did In World War 'U when ture the Occupational Safety aad Health Administration fOSHA) may promul gate a regulation designed to control car cinogenic substances. ' Should this regulation be adopted, it would be undoubtedly the most expensive Government edict in history. Capital costs for compliance have been estimated by the accounting firm of Boot. Hamil ton it Allen to run as high as SSS billion, and continuing annual costs as anywhere from $15 to $30 billion. By comparison, the American Enterprise Institute places the total cost of all existing Federal regu lation at approximately <6< billion a year. And, of course, if the regulation were to become the national standard for all other Federal agencies concerned about cancer--the Environmental Pro tection Agency IEPA), the Food and 3; ths only specific mtmonoe in this category limed so far 1* "water.*' The Anal category, 1, would be rasemd for substances not used la American workplace*, he they cariino' genie or not. Should this regulation bo adopted, it would he undoubtedly the most expensive government Odlct is history. Capita) costs fer compliance nave been estimated by the amounting firm of Book, Hamilton and Allen to run as high as I88 billion, and continuing coats as anywhere from *15 to 30 blUioa. By comparison. the American Pater, prise institute places the total cost of all <utiss federal ragualtios at approximately 565 billion a year. And, of course, if the mguUtion were to become the national standard. fer all other federal agencies concerned about etacer--the Environmental Protection Agency (EPA). the Food .and Drue Adminis tration (FDA), the Consumer Prodnet Balety CommUaion, the National Cancer In we wire cut off from rubber--that It is la the national interest to build a synthetic fuels Industry. Drug Administration (FDA), the Con sumer Product Safety Commission, the National Cancer Institute (NCI), nd stitute (NCI), etc.--the met easily runs Into tbs hundreds of billions. mn is none semimne un peunsu mxnuR wvstx camat. so forth--the cost easily runs into the The OSHA eoneer proposal loads into one We must make the commitment, aad guar antee purchase of a given amount as a neces sary stimulant to the tnveetnwnt of private capital. It will take perhaps 5 years to bring the first plants on the line. St is a eound bet that, by that time, the world price of oil will have reached the price for which synfuela oaa be hundreds of billions. The OSHA cancer proposal leads Into one of the most peculiar stories of our time--peculiar on at least two different levels. First, there is a serious scientific question concerning the validity of the standards OSHA is promoting. Becond, of the most peculiar atorlea of our time-- patina? on at least two different levels. First, tbev* U a serious scientific questton concerntog the validity or the standards 06HA is promoting. Second, there Is the ism* of bow such dubious standards eould be adopted by the federal government, despite the paucity of evidence in their behalf. One is a matter of made. there is the issue of how such dubious politico-legal maneuvering. Beth deserve the Most Of all. we need a sense of urgency. We need a national molve to produce ourselves out of our difficulties. There Is no other way. Above all. we must not despair of the ability ef this nation and the American peo ple. when once aroused, to face our problems standards could be adopted by the Fed eral Government, despite the paucity of evidence in their behalf. One is a matter of scientific fact, the other a matter of politico-legal maneuvering. Beth de serve the most exacting scrutiny--by moct exacting scrutiny--by the media, and by ths Congress. Under the OSHA formula, a substance would, in effect, be presumed guilty nr.ni and unlaw rubeequeat hearings proved it innocent of carcinogenic effect. And as Wil liam Butler of the Environmental Defense sod satve them. the media, and by the Congress. Fuad contends; "You can't prove a nega Let me read you a passage from a report: "We find the existing situation to be so dangerous that unless corrective measures are taken Immediately this country win face botb a military and civilian collapse. (The crisis has cocos as result > of procrastinations, indecisions, conflict of authority, clashes of personalities, lack of understanding, de lays * (and the) failure to build a prater stockpile of erude * The naked facte present a waning that dare bos be Ignored " Does that strike a familiar chert? 1 feel that It is essential for Members of Congress to be aware of all the laets sur rounding this issue* therefore, I offer for the Record a reoent report by Michael J. Bennet, Jr., a former em ployee of OSHA. The article follows: OSSA: c*Kcn aicp rxs Pounce or Feu MCW CH.MCTW U6VUTIBK puffins The Occupational Safety sad Health Ad ministration (OSHA) may soon promulgate a regulation designed to protect American worker* from contracting that meet dreaded tive. You can't say something doesn't exist because there's always a chance that it does but nobody has seen It. Therefore, you can't say sc mething doesn't cause cancer because there's always the chance that it does causa career but It hasn't shown up yet. You can't prove a negative statement." And you can't prove dragons don't exist, be agreed. By that standard, you would have to re gard ptncism as a potential carcinogen were ft newly Introduced in the environment or tnu:in or all of the many steroid* and antiblollcs which baw done eo much to preserve aad mend life over the post ao to 40 year* That was the report of the Bernard Baruch Commuter appointed by Franklin Roosevelt in 1942 to eurvry our efforts to create a syn thetic rubber Industry. Three years after this report, the industry of alseswe. cancer. The regulation, which could become the national standard for all federal agencies controlling carcinogen* caaoer causing agent*--in the cola! environment, would Representative James Martin or North Up* on* member of Congress who bold* a doctors degree in chemistry. He wee the primary leader in volt which mad. the tFhoeodeoanngdrawDiennjgelArJe- had been bunt, and the allies rolled into Ger classify all cbsmlcal tubalaseea into four niBisntlon back off on plans to ban saccha many on rubber made by that industry-- categoric#, Those substance* which show rin under tbt provision* of thToian whose base, incidentally, is petroleum. some evidence in laboratory teste of being Claus. How. that the National aLiS^J AP00012668 June. 28, 137$ CONGRESSIONAL RECORD--HOUSE H 5415 ' hi# fiwinimiiuiid earctncfCBi b* fimflpl vlth legard lor pctanty laVo "high." "medium," end "lew" eategarita, be cu b* cxpscted to b* a [udu in that battle a* welL Ht issued & wains to OSHA at lti 1mm* mgs on Lht eaaeer policy in Wathlngtan in the iprlng ud tuantf ot 103A: incidentally. OSHA. which matleulously sought opinions on modifying its `*Dulseae* standards" la cities all across the countsy. mad* bo effort to tolielt opinions on the Infinitely mare serious problem of cancer from outside the District of Columbia. DsanvBeo anucuax popular.pms--If not the public--as to have th wall Street Journal, "the recent' galas achieved comparable statue Ln folklore as tbs bav* airsady umet some projections! in. UTS. belief that aspirin, combined with Ofttl- _fh n-- of people aged 6S and over was Cots, will Incite Intense lasciviousness In tbe 4_1 percent higher than had been expected most reserved of young ladles. Ave year* earner." MeWitiem causes lxueiRRUNT Tet tbe International agency fw Tlnwrch on Cancel1 estimate* that only we to Ave percent of cancer around the world can be attributed to occupational disease; Ihnsssse The main reason we have to worry about cancer Is because of the advances made in conquer!og the truly random klUere, tnf*oflm and degenerative diseases: Death rates, UJ. rubltc Bealth fferofc* such aa mesothelioma, a canctr of the chest (Per lOMOO popnlarinn} or abdominal cavity occurring with abnor mal frequency ln people with long term ex posure to asbestos. 19*0 1060 Martin urged the agency to develop a carcinogen control policy on rational, rea sonable grounds, based an f-isntiftc prin ciples rather than regulatory conjecture. U OSSA hu out "to ban or economically erippje products whose risk It oceaparabls to escebsrin. . . uartln argued, "you vUl Indeed, a recent effort by the Department of Health, Education, and Walfare to up tbs percentage of occupationally related cancer to 20 percent of the total was ridiculed by The Lancet, tbe official publication of tbe British Medical Society, and described la these words in Science, the official publica Tuberculosis --------------------------U.g Bheumatle fever____ ___ _______ 82.1 laduenTa/pnemrumia...........-- TO. 2 Appendicitis__________ B.O 0.1-ii.f^u^^.) obstruction. 2.0 DUhete* r - --_________28.6 8,4 9.0 28.0 0.9 8.0 8.4 not thereby reduce the statistical incidence of cancer, you wtn divert and dilute atten tion that ^ould be focused on serious esjcfaogena. you vein confound end confuse the public, you will deserve the ridicule tion of tbe American Association, for the Advanccaeat of Science. These estimates axe clearly Inflated. In each case, the Investigators have taken the hlgbeet risk ratios available--ratings ob Some scourge* of tb* past are now so rare only fragmentary records are kept on small pox, dlptherta, malaria, etc. The only death rat* causes which show a peaking in youth you trill receive. That would be a tragic ' tained from workers exposed to massive con and early middle age rather than old age are, parody of the responsibility you ought to centrations of tbs carcinogens and multi not unexpectedly, suicide, up from 10.8 la excrete*." plied that by the total sumbar of workers 1940 to 144 in 1980 and homicide, from gh OSHA has apparently refused to heed that who might nave bean exposed to the car to 64; all easily explainable by a greater warning. and metead. baa cnoaeu to exploit cinogen. even though most of tbe workers proportion of the young in tha population, fear, chat stark. unmeaning fear which PrankltB Roosevelt spoke of In another con text: "me only thing we have to fear is fear Itself." This approach Is coming under increasing attack within the trteatiSe community, by Individuals, the National Academy of Sciences and the American Council on Sdtnee end Bealth. composed el such distinguished setratteta a* Kerman Bot- leug, winner of the Kobel Pi lie for tne `Green Revolution." Dr. Frederick Btsre, formv heed of the Harvard School of Public Health, and Dr. Philip Ooie of Harvard end tbe International Agency for Research on Cancer. The council recently ictzed a `pant* pttfat entitled. "Oaaorr in d United 8e#t**r Is There, an F^Memler" The pamphlet contends:' "Basie statistics about how often cancer strikes and who ft affects have frequency been distorted, and basic knowl edge about tbe causes of canes overlooked. Ironically, the overall cancer rate in the United States has been declining sloe* 1947. The only form of etneer which has Increased slgnideantty la lung cancer" mostly attrib bad never been exposed to the concentra tions on which the risk ratios wen based. In a similar analogy, one might And that the risk of a driver dying In aa automobile oraah la one in ten tf tbe automobile Is consistently drtvsn In exesee of 120 mllas par hour, and there are currently 100 million automobiles on American highways. Using the logic of the government report; one would conclude that there will be 10 million excess deaths as a rvsnit of driving at high speeds." Scleoea also took a elate look at the Agues eked oo shipyard asbestos workers In War H, tbs group meet regularly referred to tn articles wrtb titles like, "ls Tour Job Dan gerous to Tour Health*** Seme four minion of these shipyard worker* were heavily ex posed to asbestos during World War H. Tbs HEW laveattgaton prediet about 14 million ara expected to die of aabestce-rviated came* enough to account for U to IS per cent of all tbe cancer deaths la tha muted Staff* Yet only 1,000 cases ef irKwotheTmla are reported annually--not the ?J300 that would be expected if tbe prediction is to become true, and a* that rase, every worker should xinuii wniiiiMi w scxwo Every disease now llfltrrt fry 'In PiiMTit B8UIS BerviCR 11 UiGiarUy a Cl--nf *3A germing-and gb etilng as tapestwLluir population of the elderly declines. And thanke to the conquest of disease* eueb as polka tuberculosis, pneu monia, even diabetes, many more people are Ma^hlnv that, mirm nltltri*tArita nf !,,- ffr flf flfirt finest* A chart troor'tbe Public Bealth Service shows, quit* clearly, that both ef thaaa aQiaiom kill approximately the same num ber of people In tb* early and middle stages of Ufa. until at ag* 40-M. the heart disease rate begins to climb until it doubles the cancer rate at 65-69, triple* It. at T5-7fW quadruple* It at K-44 and quintuples tt tx 85-6S. DtetKi /rum cower sad cariKovsrewfar disease--13?S. Cardiovascular Cancer disease utable to dgsrutte smoking. he dead by now. Iretrad, 40 percent art still Tat, Che council argues people have been persuaded cancer la somehow "the fatal haw . within modem society, the grim ahsdotr as S the feet of technology, lurking in the food we eat, tbe water we drink, the chemicals we work with, tbe very air we breathe." alive. "Sever* dadclmelM (exist) In tbe original report and nrcesmmc the conclusion that its predictions see Invalid," tbe Science article nrninHirta* Cairene ssans MoaartMtr Age: Under 1M.--. 1___ 129 131 S ____ --____ -- 1W 9_____________________197 4________ 216 The mistaken premise on willeh tbe eencer scare la based apparently originated with a simple statement of fact by the director of tbe International Agency on Cancer, a World Health organization. The statement wae that 70 to 06 percent of an cancer Is environ mentally mated. Tbe word `environment" was meant to laeiude eultujwl facton sueh. as cigarette smoking, overeating an excess rate of stomach cancerIn Africa, far example. Is attributed to too much consumption of peanut products--and other aepeets or per sonal lifestyle. The most common site ct caneerous development ts tbe akin, due to ever-exporm to tbe eua. a problem not too often faced by workers In Iactedee, mines, even shipyards. Nonetheless, the statistic was picked up In lie distorted form and repeated Often enough, ever and over again, so that It be came, 1& the words of tbe cuntil, one of those statements "that Just won't go away." According to Dr. Michael Halbcrttmm. / editor of Modern Medians, in a recent arti cle for The WaebisgtOB Poet, It has taken Indeed. HEW Secretary Joseph CalUano ha* told tha American Cancer Society there la mminting evidence that cancer la being brought under control: "Cancer mortality rates, particularly the kinds that affect children and young adult*, have declined. Acute leukemia In children, cancer* ef tbe bene and kidney tn children, Hodgkin's disease and other lymphomas are sew controllable, often to the point of cure. EMU ef tbeae triumphs has coma about through, knowledge or tbe better application of knowledge. As a result, the cancer death rates for all groups under 38 Is actually de clining; for the 8* to 89 age group It la badtar steady. Only above the age of 63 does the rate continue to rise, and there only slightly." From a life expectancy of leas than 80 hot more than a century ago, ln 1077 the Ufa expectancy a* birth rose to 732 yean of life, according to recently released ftgurea of the House Select committee os Population. Moreover, tbe nation's death rale In 1977, at 8.8 per 100,000 of population, was the lowest annual rat* ever recorded, and IP was the under mo M____________ 989 10-14__________ 878 18-19 , ------ 1.937 20-34 __________ 1.442 28-29 -___ 3.913 30-04 2.670 35-39_________ 4.113 40-14 7,949 43-49 _____ I... 16.099 80-84 __________27. IDO 85-59 ..... 37,136 60-64 ....._____ 48,019 89-69 _______ 84,379 70-74 ......... 83.525 75-79 46. Ul 0-84 ......... 85,126 65-89 ________ 18,977 90-99 __________ 6,360 95-100 ____ ____ 1,176 1004-140 Total ---------- *68.893 617,047 And yet. no on* haj aver disputed that aueh a tenacious hold on the mind of the figur* the jtar before. Indeed, according to heart disease la primarily a disease o( aging, \ i ! ..I t' K r i APOOOt 2669 U uiJLb COiNLiaa*iOINAL litLOKD--HOUSE June ZH, 1079 *z the heart, arteries and vein* weaken usd Most Important of rU In fert&gtna about The "handful of tndependsut outside eel* fis*rfa. ft (M9I not Uill'etiOnable to assume adoption o! the standards. hnant. T. been enlists" Dr. Epstein refer* to are among e--a--a--&--e--e-jd--ev.e--lopsI-n the tLiiu--ea-of*th--e elderly ttl, little-noted Interaction of legal-minded t&ose who bellsve cancer la primarily caused u 'flier, toe. age and the body'* defense envlromnenUlUts. In and around the fed* by enurowneaui condition*, from chemical* mechanism* weaken. erat government, working by circuitous in the food we eat, the water we drink, the "The public should be aware of a fact that mean* to tut ofllelsl poller la the direction au we breathe. Another school of scientist*, 1* common knowledge among gerontologist*." of erlppllog regulation. larger In numbers but with considerably leu Dr. Herman Biuementhal. research prolessor of gerontology (egtng) at Washington Uni versity, st. Louts. Missouri, wrote Id the Sep* um&*r. 1B?8 Harper's. "The eradication of cancer would add only ont to twp years to human life expectancy! a* opposed to about 10 yean for all forms of anencacltrcels. The potential gain m Ufa expectancy if the rata of aging could oe slowed and the possible influence of such a strategy on the frequency of cancer, arteriosclerosis and other diseases e! aging--bai net received serious consider* atlea. For every 42 w* spend on cancer re* search, only about 3 cents furthers research on aging." cum online a uttx UWrtM MASTTXMINPD POUCT The two principal architects of tbs OSHA cancer policy are not scientist* but lawyers: Anson M. Seller, special assistant for zegu* latory affairs at OSKA. and Anthony c. (John) Kolojeskl, president of Clement As sociates. a Georgetown con*lilting firm. Both men are virtually unknown outside of a small circle of associate* and colleagues; neither hat testified before Congressional committees; both have assiduously avoided publicity; yet together they may yet exercise mere Influence over the environment the working conditions, the economy and the health of America than all the fabled name* or Washington, from Nader to Meany and Impact on tbe Instruments of mass commun ications. believe* cancer it essentially a dieuse of aging, precipitated by smoking, drinklng. and uttns habit*, and potrlbly prede termined, to tom* extent, by genetic trait*. ueu kuMtTts (3'ua But although tba scientist* may debate, the law u etui tbe law, sow a* when tbe Inquisition decreed Galileo was guilty of heresy in declaring the earth revolved around tbe sun. The current law of this land today on eaneer la the Delaney clause of tbe Food and Drug Act of 19&6. the very clause in voked by tbe Food acd Drug Administration in iu thus far unsuccessful attempt to ban eaecharin. In other words, the propo*--< obha stand. Kennedy to Certer. The manner in which Keller and Solojeski. however, were quit* Aee -an ^Vn-rjir ar# msi^Uet.e --- they have exerted thl* Influence la one of ueeeasful In using the Delaney Clause argu spans# to a totally sUartated aroMm There the great untold stories of contemporary ment to boa aidrla/delldrin is their brief be if Tin nr.f 'nidnw in tft* Pnitafi Btatas;. politic*. fore the EPA administrator. there 11`litJ niiUuua iiieL gCSiiise utT The work of Keller and Kolojeskl has *Torcmcst of tbe regulatory amendment* jjave Is caused by general environmental in* been publicly recognized as yet only in The la It* offer of informed guidance," they said, __ii_w__iw_in--TI'l'TiFiint^nll?^i*l*Uhr*rTTrfTfl 1'1-1 trhtfirms-tn41t1 '* res ton to .Politic# tfl nimn rnflt y Gostein. of Cancer, a the sciential book bv Dr. Samuel general!? credited as r~uuia SB k&yifllKg iflfi erorj uiillg In the an- being the grey eminence of the environmen* "U tbe Delaney Clause, in effect sinca less, this statutory prohibition constitutes the judgment of Congress that the addition of Tlronment--ob the ground! that we don't tal movement. The Politic* of Cancer was an? amount of carctnogenie chemical to the know It doesn't cause cancer--will affect the described In a Washington Fort review as food supply, regardless of it* purpose or authentlo cancer problem In any way what* "a compendium of all the Information on value, is hazardous to publle safety, that soever. the 'environmental* eauses of caneer that a chemical which la carctnogenie in labora son ccs or the httb If all this 1* tbe ease, bow did the pro* posed cancer policy of OSHA get this close to becoming actual regulation? For one thing, tbe environmental move* meat has enjoyed a certain moral ascendancy ever recent years, and become a rich mine of quotes, pltcuret and stories for the press-- yellow journalism for the upper middle class. Fum from smokestack*, oil spills on pris tine bays, workers in hardbat* make far more dramatic TV Images than people eating and drinking and smoking--probably the prin* elpal causes of moat form* or cancer. And at least is the beginning, many of the crusades directed against abuse or the environment and tb workplace bad merit. But along tbe way. tbe movement picked up its own constituents, the lawyers, the lob* byists. tbe ``advocacy'* scientist*, the publi cist*. aU of whom wanted to do good and often did well in the process. Unfortunately, soldier* In civilian crusade* don't have tbe same Incentive to pack up sad go home when tbe battle's over. The battlefield of environ mental ehle ha* its own enticements. Moreover, few scientist* were willing to take public issue with the environmental* 1st*--and the government, fount of almost all research funds. And. as a partial conse quence. few critical studies of the assump tions and presumptions behind the move* meat appeared la the press. Dfpt7ST*T chxmt 3b addition, until the movement of tbe OSXA cancer policy--aa the new spearhead and battering ram of the environmental movement-industry had also failed to take any unified action. And it did so only with tbe formation of an organization called the American Industrial Health Council, an ad hoe coalition of companies and trade asso ciations formed essentially to pool tbe eoets of legal meters ticking all the way to the 1* probably going to serve as a Bible for tbe forthcoming effort ... to drive all earefno* genie material* from the workplace and tbe world." Dr. Epstein peyi due credit to Keller and Kolejeskl in The Politics of Caoear for the early work they did la establishing the prls* cipiet oa which the OSHA cancer policy rests. That work was done back in 1973-71 at the Environmental Protection Agtncy (EPA) Id proceedings calling for the ban ning of tbe pesticides, aldria-deUdrin. "The (EPA) litigation teem." Epstein ob serves, "was headed by Aason Keller and An thony Kolojeskl of tbe Office of General Counsel. This team started work tn virtual Isolation, as the OflSea of Bestleide Programs, where the supposed scientific expertise oa pesticides was -located was. end etui Is, highly eympabetic to agr1-hemleal interests, quite apart from resenting tbe Office of Gen eral Counsel* policy-making trends sad ease ct access to t&a administrator. . . . The Ofiles of the General Counsel was staff ed by young, environment-minded lawyers. The bitter schism which developed, known as tbe `scientist* ts. the lawyers' largely re flected the fundamental political ambiva lence between environmental activism and traditional pro-Industry conservatism." SOSatHT SCSXTlSTt COKICilD To Dr. Epstein any scientific evldane* ad duced by any scientist who has ever worked for or been retained by private Industry is Inherently flawed and ucwortbv of con sideration. Apparently Keller, Kolojeskl and the EPA Office of Oeneral Counsel, felt the same way, and given the "failure" of tbe scientific experts la the Office of Pesticide Programs at SPA "to provide scientific as sistance in tbe proceedings. opened the doer ... to go outside the agency." ``This however." as Dr. Epstein noted, turned out "net to be so easy. Most university agricultural economist*, and entomologist* receive research support tory apeclee constitute* an unacceptable risk of causing caneer In man If present in tbe food supply. I.#* additives to tba food eupply which arc carcinogenic in laboratory aro^sie must, perforce, be assumed earetnogtnlo fa mao." On the face of it baek in 1974-73, the argu* mint made soma aenea. la the particular ease of aidrin-deiidrUs. the substance could be considered a food additive since tt could be found pervasively in tbe food chain. How ever. there are several problems with tbe argument, For one. substances that produce turnon In animals, eggs and laetoee, for ex ample, do not aeem to affect people, and by tbe same token, anenlo and benzene, which definitely do not cause cancer in ani mal*. moat assuredly do cause cancer lfi people. Moreover, the caneer risk to workers does net come from a pervasive element la the food chain. It doet not come from direct Ingettlon through drinking and eating hut through the akin and breathing passages with their own highly sensitive and complex defease mechanisms. It is not an ever present danger, but one encountered eight hours at a time, over a working rather than an actual lifetime, and with tbe aid of protective con trols. LXSAL CKAXet UCOifUENOES Indeed, tbe National Academy of Science* has recently, after a year-long study, recom mended to Congress that the Delaney Clause be amended to refleet tbe reality of relative exposure! to known or suspected carclnoztat. "hlch." "medium." and "low." Unfortunately, facts often have a hard tune catching up with perception*, and legal precedents are often Impervious to realltv for many a year. In any.eveat. a legal precedent forth* presumed control of eaneer had been established by Keller and Kolojeskl la the case of olfirtc/deiicria. xim BZLLEx-ttOLorztiu tuvrru Supreme Court. Ob top of that, the cancer hearing took place exclusively in Washington with little or so pubiie attention and leu media scru tiny. And so OSHA public relations campaign of eliminating "Mickey Mouse" regulations had scored with the newspapers, and TV, di verting conoera away from tbe bearing. from industry and were unwilling to help the government position. The majority of xperts on toxicology and earelaogeales who were approached were either in a similar position or unwilling to take the time to help. The government case bad then to rest on the effort* of the small litigation team and a handful of independent outside eclea* tl*le"-- emong them, Dr, Epataia. Kot much later, tbe two lawyer* we-e tn leave EPA. Keller to go to OSHA andKOiS jaskl to ferns hi* own firm. Ciearot Assoel- ,osaA- Keller, as special assistt* Aligned, in -.top PrtwKy to proimfl* ssa-aS AP00012670 June 28, 1979 CONGRESSIONAL RECORD--HOUSE H 5417 .lath* Delaney Amendment. subsequent rule- esting Questions of late' ectual sad contrac making is. however, individualised." tual proprfaty might hare been raised. Dr. pt*ta did nbt mention that Kolo-' eeax-cLKSACKv iwmitSAir east. je*kl would be providing assistance to Keller both in the rormulatlon of generic standards u well a* la the subsequent rulemaking on individual substances through the magic of federal contracting. The new relationship between Keller and KoloJCikl did receive some public attention in a Wall Street Journal article published oa In October of 1979. a non-eompeutire pur chase for a grand total of *10.000 payable at the rate of sis an hour, was lee to Clement. Associates by OSHA. The OSHA contact was Anson Keller. Such contracts ai* normally let to purchase offiee supplies or the services of writers sad artists to prepare annual re ports. pamphlets, brochures, oto. They are not October 11.1979: customarily let to develop social policies Waskinc.toh.--A peculiar question hovers affecting million* of Americans. This contract ever the Occupational Safety and Health lor 110.000, however, was to develop "Alter Administration's effort to produce a sweep ing new policy for regulating cancsr-eaustag native Carcinogen Regulation." eves though NIOSH. the sgeney created by Congress to substances at placet of work. The question: - develop *ueh policies for OSHA. bsd seen its When OSHA sponsored a long series of carclnogenlsts budget increase from 91.9 mil cancer-policy hearings last summer, were lion in 1979 to *9.9 million in 1979* reaching OSHA oOclils there to hear the testimony? 910.7 million in 1977. "OSHA oScials insist they were, in face, But for a mere 910.000. Clement Associates they add. the hearings were taken so seri was presumably prepared to do the following: ously at the sgency that officials at one point Scope of Work: found it seeetsary to admonish Eula sing- The contractor shall examine and furnish ham. the agency's director, to atop spending alternative approaches and policies for the so much time listening to testimony to the regulation of carcinogens: and shah examine exclusion of other pressing problems. Mean OSHA regulations and proposed regulations while. many of Mrs. Bieghaa's top hands for carcinogen*, providing recommendations stuck around throughout the proceedings, for Improvements is or siteraatlm to OSHA the agency says. "But other government officials, who say they sat through the entire 10 weeks of tes timony, insist that OSHA policymakers were absent during much of the bearing*. Labor Department lawyer* were there, they say, and OSHA officials dropped by from time to time. But generally, they insist, the hearing* Initiatives. Statement of Work: The contractor shall provide highly qual ified professional staff with appropriate background to deal with the following tasks: A. Survey existing federal regulations and policies for carcinogenic, mutagenic or tetragenic substances. Provide comparative anal were dominated by executives of an outside consulting firm called Clement Associates, Inc.: tbat firm had been retained by OSHA to provide scientific expertise in evaluating testimony, finding expert witnesses and de termining which eubstancee eheuld be regu ysis of regulations and policies and prepare a critical evaluation of effectiveness and problems of both implementation and en forcement of other federal regulations. 8. Develop* prototype regulations for con trolling employe* exposure to carcinogens lated under the proposed cancer policy. found In the occupational environment. "Many observers In Congress and Industry believe OSHA* recent cancer hearings re veal a certain ecleatifie elosed-mlndedness at the agency. They point particularly to the role of Clement Associates, which performed much of the work that normally would have C. Providee position paper* on denning carcinogenic agents and on OSHA regulatory policy for those substanoee found to pose a carcinogenic risk. All of thst--for a mere 910,000--seems like a solid investment la the healtn and been performed by officials of the National safety of the American worker*. Unfortu Institute of Occupational Safety and Health nately, we will never know what that 910.000 (NIOSH). bought* "Some NIOSH officials feel tbat OSHA. de mo xrrocr zvn sterna parting sharply from past practise, purposely excluded the institute from the process of "No formal reports were asked of Mr. Kolo- .hipm, th, hr p,^. NI05H cmci.u 4"^; weren't invited to testify at last summer's hearings, and they couldn't even get copies of the proposal until Just before it was re leased publicly, they oomplaln. "NIOSH was completely bypassed." aays the institute's deputy director, Edward Baler. "To what pur pose. for what reason. X can't say." "OSHA.officials dismiss the complaint as coming from an agency that lacks high- caliber scientists end bends too etaiiy with the political winds. They, also dispute the notion that KIOSH strongly influenced the agency's regulatory actions a the past. But other* view things differently, concluding that NIOSH wa* bypassed because OSHA officials didn't want to deal with as sgeney not always In sympathy with OBHAU regu latory outlook. "According to this view, OSHA sought the asst*time* of a more sympathetic organisa tion. Clement Associates. OSHA'a critics bol ster their case by pointing out that th* agency's top lawver In the cancer-policy area, Anson Keller, one* worked etoeely at the Zb*-, vironmentai Protection Agency with Clem ent's president, Anthony C. SolojeskL At the SPA. the two pressed for many of the same policies that are sow incorporated into OSKA's anticancer proposal." The Wall Btreet Journal article did sot go deeper into the relationship between Keller and KoiojeakL Had it done so, eoms inter- vember A 1B7S. In reeponse to a freedom of Information request. "A* a matter of expe diency, the input to the agency was in tbs form of briefing* or dtocueelons of Issues, handwritten or typed opinions and cummarlea of data available os subjects assigned by OSHA for Investigation, aad 'mark-up' of draft documents prepared by Q6H*. The documents were used, in genenl, as source documents lor OSHA staff, and as appropri ate. some sections of these documents were incorporated in early drafts of the proposed cancer policy. These early drafts were con tinually reviewed and revised by OSHA staff, and. In January, 1977, a preliminary draft was publicly released.1' uou uokcy * etmm Whatever work Clement Associates (Ud on that draft must have helped because oa June 23. 1977, the arm won a competitive contract to provide technical asalttritirv to OSHA during the public hearing on the aaneer poUey held last spring and summer. only this time, the financial terms were slightly different, net e maximum cf SIS an hour, but *43 an hour for a project director. S49.2S an hour for senior scientist*, and #14.00 for Junior analyst*, on th* basis of s 40-hour week, that runs to ISSjOOO a year for th* manager; #06,000 for the senior sci entists; and $37,000 for the analysts. However, the total bid figure on the con tract was rather low. *69,300. Tbat was soon to be remedied. On July 36,1677. one month after the contract was awarded, OSHA'* technical representative on the contract, Dr, James Vail, a career civil servant and a scientist, was replaced. HU successor waa Special Assistant Keller. Three weeki after that, on August is, 1977, the amount of the contract was tripled to 9313.000. Bine* tbQ. Keller baa signed off on invoice* total ing well over that figure. on the order of close to $400,000 by November of 1979. Mr. Zeiglcr. in a Utter dated.January 16, 1679, uld, "We anticipate that further payment* will be made for services rendered as pro vided for in the contract." Clement Associates carried out It* respon sibilities to' OSHA under th* contract through two task order*. The first order, labeled "undated" in the monthly Invoices submitted for payment, oalled for screen ing 1,500 suspeet carcinogens identified by the National Institute of Occupational Safety and Health (NIOSH), On April l of 1677--about three months before clement Associates was swarded the OSHA contract--the firm secured another contract with the National Science Founda tion to provide technical assistance to the Interagency Advisory Committee established by the Toxic Subtleness Control Act. That, too, -wa* to screen the 1.900 suspect carcinogens Identified by NIOSH. The first phase of the multi-phase contract was for B142.7B3 for 3.140 hour* work to be com pleted in three month* or by June 33, on* day alter Clement Associates was awarded the OSHA contract. Th* clement Associates' proposal to 06HA referred to the fact it had already obtained a contract with th* Interagency Advisory Committee to do essentially the mm* work: "Although the criteria to be used la setting priorities for tasting under th* Toxio Substaocm Control Act sue not iden tical for regulation under the Occupational 6afety and Health Act, the overlap is suf ficient to give clement Associates valuable insight and experience into this task," tbs company's proposal to OSHA reads. The primary source of raw materials for both project# is the list of suspect carcino gens updated and published annually by KIOSH. The acuaufic data are obtained by fcirwmiwg the scientific literature, * task often performed by graduate student*. It should be dearly understood that no attempt la made by N106H to appraise or usui the quality of the research. The list is published In book form and also fed into a computer. The information can be bought from NIOSH either. In the book or the computerised form. Dr. Geoff Taylor ha testified Clement Associates `like everyone else have requested eocesa to cur computerized information lervlce which is oalled NT06H-TZC." KIOSK COTU> BAYS B9NI TV re* LESS There it Uttie reason to believe NIOSH eauld net perform th* task assigned Clement Assoclate* for a fraction of the cost paid Clement Associate*. v For once the data are in anyone's com puter. and they already era in NIOSH's. they can easily be broken down In accordance with previously established criteria--a task that can be performed a* readily by NIOSH at anyone elae. As noted before, undvr Clement Associates' contracts with both tbs National Science Foundation and OSHA. it is dividing the suspect carcinogen* into three similar cate gories: "On* eleas will eonaist of those cbemieala which arc in production and for which strong prims fade evidence exists thst the chemical t* carcinogenic. 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Snjp eta cxoixom ZZ na ot auodaug aqt ta ttnsaj au `Btaiax* Xiotuoxa am qdruuqs aaoda^ am sno qsnp ot poXotdoia siM *poosq am tit aiA! taj jo toxat*ioqo aaopaj m uotoop Xq paan Xtsnou -aid ffzup y ooittB!nu'q oaaa 'no( Xtotnaoz lodojd tuajjna am Xjattcr.uojti.i.. -nod eepjao fnttarn*3'* jo; Xonod VHSO pasod oid am u-,13t> os no scom Xpntc aqx * *opnaaj *som ataajua taetu am tnq nanT'anonoa *it ;o fttoo ap&onooa am laptaooa os ivinjai *TT XutcnsiSJtd tuiaiqojd mnannptmj aiotn c.VKSO tpovaauaMim ai anpartdo tpnfl tdo Asm am no aim cpitpoata acoqs jo ssoar stm aos pa.tiot uaaq nq .taatqoid VHSO. wqt #Anq RT- ardoad atoo* 'sttiaai ** saqt jtaj aAt *pap]n3ffut Innopto o* J8M qumto MR aentsaq tnd m 'apiaptm* anmrntx aqt jo aaoas jodtot m pasfaandmuaao XrsauS atq ttajd jatnded aqs or lenu* oaom iiiarnan -aad i3Ut*.ya90 sam aaanaq iA A|rod x> Ijm oaaq ? nram mpe aotzartdtaoo Sam aMliaq os oocsm antTT V tm 'ttna ooddo .yhso xi taMpoatrt cnoaButno jo Botmara jo aonoc q*VJ a paptaoid attq pea ualaidm* Ina pas*|m^n axrq apnptratp aontaiRtx aqt qOTaqsrr 1*oo tq coortonpaj jo mc*>q proa Xtraa rtnontdnooo Ut roiaj totavtaJti jo enro m cam Jwnw uirno Sasoa naoianq jo Soioacaai a poa VHSO joj ff-raq sttqnd jvas*q * J amzat tr XnntnJd pazi^ax aq os XiaBTl ** `jaatMoq ipnputj* asam flattaanano nnsij ctjfti qx *patdopa oaaq t&aq ppsoq* sms tcoty 'anpjaao 3ooi t xpiapoata aotncmtl ;o -uonvnTtxrn* aqx,. WMIIBIII ^ limifL. jqTgMMttq atsiaq a07 at acnoaaq a 'tntiatmts `uoaaan pasnao 'tat jjottjoqai a; anudoupxaa aq ot bmoctu 'auodagi am. anaX tcaoa*BT anaatp laocnadnaoo jo ara paapit * * *pasauiuni aq prno.n team -tatjvq ssaamaacil jo torn a cr ArmanJd naaa XooaSa na poa *paA*a aq ptno.s tnmi ax rttcttaojaaoJ pot. *r*i?;rf tovomoSit tmuiu jo wjp.as* am uzojj Bou<ut -^o \ VHSO *q papuatotuooaa Mm joj ootsduaiajd ;\iiaj --*mnj Xtosanzistfi poa--injasM.it**t*iax* ijpmtd am cam "asnaptud pna affpajMouq aosvai no partq 'nonniot ir.;doq ucm cprcn t oj Jim am sniod Xans tag -aimaac 003 jo iino a t J|jom nTM zatSaisJis otjjs nttst pna tTs^janx aaacn Xiutamua moh -aMTp anonaatm jaqrai o pant trr nirwt,i Xr.n aaia* am qanm ej ftt m poajao pt* n;a o\ o puv V c!m*ia n taatmaqr.i isaitoasq qana 2b; xn Xq aim op <n StnXt) an nrisai:* p ____ -jldd* Jaooao panao damt fonuoo jo sno am **o? -aq--soamSozd so aensprn fleunp--jattaaa cranio nasoJd ataaaip aps idaomu; ot Xj: ot at .nonna4.-douim. ponao io?i aqj, tw*o:3 tcaoJirna a sauna** tt tjten. aaa uaa n t.oep (naiazaiqd Jnano;;ipaiw pivap Kyiop pea azintmacB Xats ltm m*OJ* toaoimw a oim i4iu uaa tt so :at ot taam ou wwl poa Xfj.oir MO-tS caa n inaddtatp jo *:j j ms boi( atu. "oaddaq oao afluim awi jo np 'aPti rnn av aaotui mojaaotsaid pttraa zaapaa jc iiapnrunoj otm Jatsn:a in patatnnr am '*** 'atdsad B|*uaa or.. uiodg *jq 3.(a ,`osp aanb nmotza b umdojtf i; iiy.g^. `no -mo ot .pgtanraT, B**d P uoXja -atmaa o taafuiaqa jrmnv 1 KJI at ipoqoa aantg qr.tf isovfl am sdcqjad--*nMados tn taa;d taoiouqa a s* aoodas Xq pauoa -lod tiatjoa zz paAioAoi rsaoatv* toaamoffia Stocs aq ..'SH*3 acqajaain* panoja ptatqa JhtpnOTtutai jo pm* a Bantu* iq oooats >qr.a Sotsnaa jaouta a jo toapa aqs aaqaas mu ottXtM^ mva pauodaj uaaq aaq acauna tutopiuScp *uao amajtxa ttoa am oj oa *anJi aq os too oa*o<ui oaaq moo vvq saqj, ijoam ,.p(oq*m oo 'Jiq-aBo,. am no pasaq-^aouvttqna tool >Bitqa Jaqto Xjrcotap taonn am aa Xom aum am 'Wns ui stuaSa 3u;snta Jaoota jo sasop t(sp:i Xino;ap ton pinm ipoq qs S*m jau aq aqt ot paq|J0qns sit!tua;o iotta 'atnvo Xaaaa *qt MajSuoo oaq* 'oia uaaX OS utm *JOK '3B;p5a%ijpun pci tSpacMoaq so as tivq a snd oajj `jjqtquj nao pea ~-a>cato pooS a^tui too taop Mtt P*q ma *atndt!p tn too an tat; aqt uq Attpaas jocq <m lit X[<idt tij.a Si 'jiuia J'ajjtna son an am anqit avaa a taut puioia aq nao i&tao)Jd juanaO a j; saqt 3u;aq aap; ant '^*1 POOS amis casta pvq Sm ajaXAt) Ssoura 2otXta p;a u xi uaqj, SOI3MV .a&tmpcsd scout aq pjnoM Xam ajaqM taan ot tsaqt 2ot toaJip tusiaBaajatm ni cn^nonax ot vbso Stjncstia ptaoM soatnajniiiaJ a qong '||ait iam *oo Nnoiaj am pna otasaad ptnoM xuaitBumoi esi Cipauaq miaaq aqt mq os ooitBaitB naitdxa Xtd ot XaoaJa am SO)-nnb -j aiapnaw c.VHSO aniniaiaj ptnotjt aj3 uoO oottniaooo jaitit* jno taejojojax aoua uadxa tsaoati qtftaq ,cia*ioja tit tnauiaAoid ri[qajn*aaai oapn* 50 pttiom asardqjaa am oi qtiacq poa IHW papoaqtrp aq pjnoqt VHSO `anlia p|noM > cxaaX oaiat i*ip ti; jo awnoo am no amnsnoo cam jamav.. XtSJtA -fnfl Piaaiaff sosovcmuaaoO JO (ooqog Xpaa nas i snor *m 'Xanod otxqad jo jom; -ojd tctwnt `qomi.'C tiaqlT pns `Xtuecoa rtonnod jo joett^xd 'jnnsmiMZ priqatH Xq paqajtatai poa oatsiJM n. tJodai aq fioia) orwqd'ua 0Q lnq xtnroqK aaoto nr Snjnaddtiq n.s tQM paatacct 'BWJtQIH V tatqajqv pco Xojad "R so[jyqo fjoiauas Xq pa-Tiqa 'cxpcrv imdacnjo.-.eo oo aaintstsoo aivcas am Jo; pandoid ucdaj piPw0 vxiuuuir naiaid nv oottpqaboi Man a pna com aiaq to* aJaXMai aqs 'sai-itT aqs paa nnsuataa aqt o*Mtaq imtq aqt oj `atuscuc3np inn Ssruat jaqtJn; Xct ttqa jo naipjadai--!<u;C03 laptm aouttiqrit aqt doiato XwdtsQid. v;,m 'nonsinSai isBai totnoo aq Xonod jaatno paaodoid aqt jj 'vjisO 'potsjejjad aq m ,.3ninat jo; cots -ajaptreoo xtvoud.. aaouatnint am a.-.tJ nt. 'itsodojd eti in tataoipw tttttsotty to*--ao sa aaiirnmoo )H1 **oon9anox; aousios lauotttM aqt Jo aoitltonog ,leoa3ma; aqs pm vhso Aa auo Hostits os ?a3ins t? rr> piuqo aqt aoso coaddaq ytqM n; 'ja-va-tioq 'aauajajjip aiquapPcotM a aq rim ajaqx uamuapxn aq A;qs -cmttjd ptnoM qomtoj Xjotajoidxa jaqur.; aioou tnq 4ixM ptno. nontf -nSai on 'I'mitnaqo jo ert^ pint aqt iOl wotsaj anautS aaoBBon jo *aoitarpaj `irtai u>t ** & amii jo; oxntaj at nans cnouuooa ..litidoj X(jaa oa utpatuac -maqo Aq--patatns--i. anioa or pjJmm jo ajnttpesdxa am aq H- iato tinoax m. -ajd aq pi turt P^0 VHSO os anrti inna at *n*a am m Ta?J*t*ss anaoa9 am *p*tat;TUl taaa.uatai }j ajojaq npaoaq jo ttaoa Jaqvi* tid jo aq ppioq* catrijo o.s aaoqt OT *]0[ q pno jacoTp 'luiaidre njodff -q taaqaiTT Su^xiaua at SMjajut mil mq Xauaia aqj- umr> jo notiWCTlOTPT 'paffr.ntf imaas non J<3 .Jos ay tnadd* XauvoSnaiB am ajo^q * 'fpjxzaq anotua Xinjj jo tjnSai oo taqs asaTJdojddant oc aaneodna ,*o wi o( m off 3ap<*i Ananin saaaojd aaaarna SOtltao aqt n Xiqt**ai Ssipaai 't.YHSO BO| catnoi jo naa.a oc cr Xiunov aroa2DO|3-*t3 jo 2aof rr si moot wagajaaaaj1 anotJoiaXs mt pnpot *t*7Jnocrj aanoa *tbdisryp niM tatod ooocptaa qbrqM iaf jo 'i[no araotLir-^ 'onat* vt uoaoo jo UDpnqofQl pm am wtp.vi.. ori )vmjr9 am ;o 'pTOJddt pjsnsojim am >w soi pntTpcud 'CCTPnpojtf so ino J*wj ezer *sz &unf asnon--craoD^T tvnotssh^dmod STM TT.