Document RJ3Q0p17mNLJy6242mVjkyKkn

Asbestos Information Association/North America 22 East 40th Street New York, N. Y. 10016 212-689-3378 August 3, 1973 DISTRIBUTION F. H. Lar'rison Q R. O. 'Adrien D RK.. JJ-. ,w --J J.,\V ^ A. A. / r.A-Ce r~ r. ' ~ n [ i Mr. William S. Sneath President Onion Carbide Corporation 270 Park Avenue New York, New York 10017 Dear Mr. Sneath: D. E. C : D. J. C-*-rd3 G. L. Vc:;s!s M, K. West File Over the past two and one-half years, the Asbestos Information Association/North America, of which your company is a member, has played a major role in defending the asbestos industry from unwarranted and irresponsible attacks by government, labor, the press, certain segments of the medical profession, and by various environmental and consumer activist groups. While most executives within the industry have kept up-to-date with developments on the asbestos-health front during this time period, many of the details relating to the genesis and current status of the overall problem, as well as information on AIA/NA activities and accomplishments, have never been collected in a single document for industry dissemination. This deficiency has now been corrected. ' Attached for your information is a copy of a presentation made by Matthew M. Swetonic, Executive Secretary of the AIA/NA, to the Asbestos Textile Institute in June. Entitled "Why Asbestos?" the speech outlines the growth of the asbestoshealth problem as a national issue, the philosophy of the nation's press with regard to asbestos, and the efforts being made by the AIA/NA to deal with the problem- on the medical, legal, governmental, customer and public relations fronts. We hope that you will find this presentation to be both comprehensive and informative. The Association will be producing Mr. Swetonic's speech in booklet form in the near future. At that time, you may wish to obtain additional copies for distribution to others within your company. Sincerelv, John H. Marsh President CC: William C. Thurber RECEIVED AUG 6 1P73 UCC 010490 WHY ASBESTOS? A Presentation Before the Asbestos Textile Institute Arlington, Virginia June 7, 1973 By Matthew M. Swetonic Executive Secretary Asbestos Information Association/North America I am sure that many of you have asked yourselves, as I have asked myself, why has the asbestos industry seemingly been singled out as the prime target for so many assaults by t 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? Are the products we produce truly going to kill millions of Americans, as some 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" is both complex and simple. Complex because it is a combination of three interrelated but separate factors. Simple because each of the factors is, when considered by itself, quite obvious. The three factors are (1) asbestos can cause disease, {2) a spokesman arose to champion the need for asbestos control, and (3) a cornucopia of new government agencies were set up to A 1 9 573 s- UCC 010491 2 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 cannot be denied, even if they do not apply in all circumstances and under all conditions. The medical literature is full of solid evidence linking asbestos to disease. In my office, I have on file more than 2,000 medical papers dealing with the health risks of asbestos and hundreds more are published every year. * Secondly, the spreading of concern oyer the health risks of asbestos has as its prime spokesman one of the most talented medical publicists of the age -------- Dr. Irving J. Selikoff of New York's Mount Sinai Hospital. Not only is Dr, Selikoff capable of arousing the ire and moral 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, unquestionally painted a far darker picture than the facts warrent, we should always remember in his defense that the insulation workers he UCC 010492 A t 957 7 's 3 has been studying for more them a decade were and still are dying from 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 decade there has been a tremendous growth in public and governmental interest 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 in this or any other country. I believe it is accurate to 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 and his followers, who achieved these ends through skillful use of the great wealth of negative asbestos-health data contained 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 attack, and because Congress had graciously provided the vehicles for such an assault. UCC 010493 A 19578 4 The background of industry efforts to deal with the asbestos-health problem as a national issue goes back nearly a decade, to Dr. Selikoff's now famous 1964 seminar on asbestos disease at the New York Academy of Sciences. While 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 and for the health and safety of its workmen and the American public. The asbestos-health problem was found to be tailor-maide for such stories. As a result, starting with Paul Brodeur's infamous New Yorker article of March 1968, 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-Manville Corporation, which set up a task force of specialists in various fields to do what it could to portray the problem in its proper perspective. While 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 UCC 010494 A i 957 3 5- of North America, which was patterned after the British Asbestos Information Committee, which had been established some 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 other government officials. It must be remembered that at this particular time, the enormous problems that would later develop with regard to OSHA and other Federal regulatory agencies were as yet on the distant horizon and basically unrecognized by the industry. I 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 manufacturing 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 Government Affairs . UCC 010495 A 1 955C 6- 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 authoritatively on a medical matter, it must not only be seeped 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 meetings, such as the 1972 Lyon, France international conference on the biological effects of asbestos, which was sponsored by the World Health Organization. I We also meet on an irregular basis with various medical experts in the field, both from the United States and abroad, * bo 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/NA 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 an individual's potential_susceptibility to asbestos disease. UCC 010496 A 1953 1 7 The Association has also recently decided to contribute to some very exciting research into a possible cure for mesothelioma through electromotive treatment. This study is being conducted at Somerset Hospital in New Jersey. In the legal affairs area, the Association participated in an amicus curiae capacity in the law suit brought by the Industrial Union Department of the AFL/CIO against the Occupational Safety and Health Administration on the asbestos standards. In our brief the Association supported OSHA against the IUD, somewhat of a unique position for an industry to find itself in vis-a-vis a governmental regulatory agency.' Oral argument on the case was held April 4 in Washington. While a decision has yet to be handed down by the Court of Appeals, we are confident that the case will be decided in our favor. The Association has retained the services of a special technical consultant on environmental control affairs. At the present time, he is working with the AIA/NA Environmental Control Sub-Committee on 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 certain variables on the overall accuracy of the method. UCC 010497 & 1 9532 8 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 sent to both OSHA and to the National Institute for Occupational Safety and Health. A number of the recommen dations contained in the study for improving the accuracy of the method have been incorporated into a soon-to-be-released revised NIOSH operations manual on fiber counting. In the customer relations area, the total effect of negative press publicity and government regulations on industry customers is still today rather poorly defined. Some members of the Association have reported serious problems in this area, t 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 make it non-competitive with non-asbestos containing substitutes. Second, the customer has not throughly investigated his situation and only thinks that he can no longer afford to continue using asbestos. UCC 010498 A 1 9 58 3 9 Third, the customer has read one or more negative articles on asbestos in the public press and has made 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 ill-informed medical advisors or safety and health directors. Fourth, the customer has neither a control problem nor is he particularly afraid of using asbestos in his own plant. However, he is fearful that those of his competitors whose . finished products do not contain asbestos will stress the adverse health effects of asbestos in trying to take business away from him. Customer fears of this nature are essentially "gut" reactions and are hense extremely difficult to deal with. Fifth, the customer has none of these problems or fears but he has been advised by a government official or inspector that he would be better off if he quit using asbestos or asbestos- containing products in his plant. While 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 officials 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. , UCC 010499 A 1 9584 10 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 presentations 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 of our member companies showed that general "catchall" type seminars of the type originally contemplated would not be effective in dealing with the majority of 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 Facts About Asbestos and Health," and "Understanding the OSHA 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 problem best handled by the individual member companies. Thus far, the AIA's sole contribution in this area of industry concern has been to prepare the draft of an Employee Safety and Health Guide on Asbestos-Health. The draft was made available to the member v UCC 010500 ! 958b 11 companies for their own use and at least one has produced it in booklet form for distribution to all its employees. I personally believe that the employee 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. We know that various organized labor groups are planning a full scale campaign to bring their interpretation of 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. 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 our overall mailing list increased from approximately a dozen names in 1971 to more than 60 a year later. While 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 on the list that the material we send out is being read and is of considerable value to those receiving it. UCC 010501 A 'i 9 5 8 O 12 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 understand why this activity ranks so high on our priority list. What you may not understand are the reasons why our extensive efforts in dealing with the nation's press have been so unsuccessful to date in producing the theoretical "balanced" or "positive" story on asbestos and health. '* The simple fact is that from the standpoint of 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, the press either says we ought to have done it ten years ago or that we should have spent $200 million. If we sponsor medical research, they say we are trying to buy favorable results. If we are opposed to ridiculously stringent standards, they say we are in favor of letting our employees die. A television executive in Minneapolis described this new breed of reporter as being "so intent on demolishing the establishment that they would blindly destroy the credibility of the media in the bargain." Another TV executive, this time in Chicago, stated "they want to make moral and political and social judgments on their assignments and then take sides. Never mind getting the facts straight." UCC 010502 A 19537 13 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 directly 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 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. 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 know, the Association is currently engaged in an extensive campaign to interest the trade press in articles on the benefits of asbestos and on industry accomplishments in the environmental control area. The trade press, unlike the national or public media, is much UCC 010503 A 10588 14 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 from time to time put out press releases on various subjects relating to asbestos-health. A few weeks ago, we issued a release on the report of the advisory committee on asbestos cancers of the World Health Organization. In brief, the report concluded that the general public is not 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 news is good, the press simply isn't interested. Nonetheless, the Association has no intention of abandoning our efforts vis-a-vis the national media. We 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 .3 ' to present the press with a balanced view of the asbestos-health situation. Our most recent effort in this regard has been the preparation and printing of an Asbestos and Health Information UCC 010504 & 1 9583 15 Pile, which we have mailed to some 3,000 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 don'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 news. And the good news is that despite all the negative articles on asbestos-health that have appeared in the press over the past half-dozen years, very few people have been paying attention. Let 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 the Opinion Research Corporation during March and April. More than 2,000 demographically selected Americans were interviewed. Without going into enormous, detail, the results show that only 22 per cent of the American public are aware of the UCC 010505 A 1 950C 16 health hazards of asbestos, and that 80 per cent of these consider it a hazard only to those who are occupationally exposed. A mere three percent of those interviewed stated that they considered asbestos a health hazard to the general public, and less than one quarter of one percent. considered it the most dangerous material on the list they were given to choose from. Surprisingly, the college age youths of America are no more 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. t 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 Dr. Selikoff and his supporters have used his research results to dramatize and exaggerate the seriousness of the asbestos-health problem. I have two charts which point this out rather conclusively. The first chart shows the actual results of Dr. Selikoffs four mortality studies of asbestos workers. The numbers in parenthesis beside the figures for total number of workers indicate those who have so far died from all causes. The percentage figures alongside the total number of deaths from asbestosis, lung cancer and mesothelioma are based on the total number of deaths from all causes, not on the number of workers in the study. UCC 010506 A 9 50 1 - 17 - & imn ci MCl cn <j\ cVoi) ro- tt0o ci in 0$ tH CO sfEah a XauXfa to zMHoEffaah fEaj oOfa u too fa ao Q A fEMah OM. fa o aftofXSoaa 3 sfa a tWo Hs ffaa os 2fa afa EH E X z o fH fa to fa \ W fa ffaa ^fa oZ to (4 aa fa Q fa Eh fEah fXa oZ aato << aa ato ofa X EffaaH Oy a2 < O<N aa tao H* o ofXa X s5 a W10 2H a o 53 X rH faa XX fa aa c Esh fa Z fa aa X Cl <faN fa <N w fOa 03 at w' in o m m CN o Cl 00 v> a 01 10 w 01 H rH in S3B Eh O Z O aa< c o XQDEWh zoM zD 8 XEh os 8 CxO & wtwso &o4 o ci *- A ; 9 O UCC 010507 18 The most important study of the group is the second from the top, showing the deaths from asbestos-related disease among all members of the insulation workers union, regardless of length of exposure. You will note that 34 percent of those workers who have died thus far have died from one of the three asbestos-related diseases. These, then, are the facts Dr. Selikoff works from. This is what he knows from his own investigations. Now let us take a look at what he has done with these figures in order to dramatize the problem. Chart number II shows Dr. Selikoff's predictions about asbestos-related deaths in the- United States. Without going into details, Dr. Selikoff has arrived at his projections by the simple procedure of multiplying the percentage of deaths from asbestos-ralated disease among his insulation workers by the total number of employees in the entire industry. You will 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 of 34 percent being experienced by the insulation workers. UCC 010508 A 1 9503 19 CO M o w Q H H OS W 03 0u h O I--t PS a W S3 CO CJ PS o ACTUAL QUOTED PREDICTION WAS 9 5 ,0 0 0 , BUT TH IS INCLUDED DEATHS FROM G I CANCER, WHICH HAVE SUBTRACTED FROM THE TOTAL.I K o o o icno z o M u Eh o a. X Ho x CJ u 05 Du o OOO* o Hr X 01 3 Oo oo o o% oTf o o tn o x XEh z ozw M s QK Q X Eh 5Z 05 <3 Q 6 5Z <4 DA Eh CO 05 Z 3 DA P DA O A h CJ H 05 ffl> X J a X 01 M X M 05 X a 3 < Eh X > o A 3 05 X s oo oo oo oo mo CN tn Eh o Xz H 2 cm > Eh r* X CO \ H jj 3 2 to s to . X o 3 i i >H zA Ha x 05 XX a2H CJ D Q H Ej O 3 3 Eh 2 05 x s M X Q X DA a Eh O XM Cu Q oX XX MX a X 05 oEh s o >* 3 X z X (N ,-- P* \X ro EH XX x X o z X M ; XNa X EH a X X XXa z i >XM M i i Xa X 3 CJ XX a 05 X 3 X oX>o wsM X Eh X n Eh X hM X X 3: o o o o o orH% s 1 1u EH 3X oZ U MM M XX a oX z Eh X H X Eh X X 05 X X M X z o o Jrt2* <+l r* Q 3 Eh E Eh \ X MX Eh X e5 <N \ X 3 X X CN O Eh : . . o o o*1 o o o H CJ z CJ H HX XX oX Eh X ZX oX >H o z XX o Eh eX XA 3 XX X * UCC 010509 A19 20 I might point out that this tactic, however deceptive, has been an enormous success since each raising of the estimate has earned Dr. Selikoff correspondingly greater coverage by the media. No finer example exists of the total gullibility of the press than the manner in which it allowed its prejudices to be manipulated and played upon in this situation. Please don't get me wrong. I have no doubt that the insulation workers are in fact dying as rapidly as Dr. Selikoff says they are. The problem is that he has translated their mortality experience to the rest of 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 be precise. Even more important, according to an analysis by the Association of more than a dozen mortality studies, including those of Dr. Selikoff, our prediction is that approximately 25,000 past and present employees in the asbestos industry have died or will eventually die of asbestos-related disease. This is less than one-thirteenth of Dr. Selikoff's most recent estimate. In addition, our figures show that 20 of the 25,000 deaths ------ or 80 percent ------ will occur among those in the insulation trades. While these estimates should be reassuring to those in the mining and manufacturing areas of the industry, we should not forget that 5,000 of our workmen are still going to die of asbestos-related disease and that, all things considered, there A 1 950b UCC 010510 21 is absolutely nothing that we can do to prevent it. The only thing we can do is to clean up our plants to assure that those entering the industry in the future will not have the same experience. Within the past year and a half, the main 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 Adminis tration; the Bureau of Mines; and, to a lesser degree, the ^ National Institute of Occupational Safety and Health, and the National Institutes of Health, both of which are maihly involved in research efforts. In addition, a few weeks ago we were contacted by the Federal Trade Commission, which had received a petition from the Center for Science in the Public Interest requesting an investigation of consumer uses of 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 those products. On the basis of a preliminary meeting with an investigator from the FTC it would appear that we have little to worry about in this particular area. The Occupational Safety and Health Administration has been of enormous concern to the.industry over the past 18 months. As most of you already know, the Association expended UCC 010511 A 1 950 j 22 tremendous efforts during the six month period leading to the promulgation of last June's OSHA standards on asbestos. I think it is a gauge of the effectiveness of the total industry involve ment in this most crucial matter that of eleven main requirements in the standards, the industry position was accepted totally by OSHA on nine of the eleven, about fifty percent on a tenth, and totally rejected on only one. OSHA is now planning to redo the standard package and we are working closely with them on this project. The first step will be the formation of a 15 man advisory committee to Review the current standards and any additional medical and technical data that has become available in the year since the standards were promulgated. Working in cooperation with nine other trade associations we have selected four individuals as industry-wide recommendations to OSHA for the four so-called "employer'' spots on the advisory committee. . In discussing the formation of the. advisory committee with John O'Neill of the OSHA Standards Development Section, we were asked to add a couple of names to the list so that OSHA would have more of a selection to choose from. This we have agreed to do. The committee will be given up to nine months to complete its deliberations and prepare for OSHA a revised standard package. This will be followed by public hearings, approximately a year from now. We do not expect to see a new standard promulgated _ before the Fall of 1974. A 1 9597 UCC 010512 23 It is of course impossible to determine at this time what the new standards will look like, however, I would venture to say that they will certainly not be less strict than the ones we have today, although they will probably be less confusing and leave less room for employer interpretation. Something will unquestionably be done to improve the current difficulties with the monitoring requirements. . The main function of the National Institute for Occupational Safety and Health is to conduct research and to prepare so-called Criteria Packages, which are essentially recommendations to OSHA for standards on various materials, chemicals and activities. Such a package on asbestos was prepared by NIOSH at the time of the OSHA proceedings last year. NIOSH will not be preparing a new or 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 agencies in Washington dealing with asbestos. Dr. Selikoff has had his greatest influence on the young idealistic scientists and doctors at NIOSH. Consequently, industry influence is weakest in this agency. It was NIOSH, after all, that made the original recommendation for a two fiber standard in the United States asbestos industry. Next to OSHA, the Environmental Protection Agency has the greatest potential of any federal agency for adversely affecting the future of the asbestos industry in this country. UCC 010513 A 1 9598 24 Not only is the EPA responsible for developing and enforcing air and water pollution standards, but the Toxic Substances Control Act, now pending in Congress, will also become an EPA function after passage. For this reason, 1 am pleased to be able to say that the asbestos industry has an excellent relationship with the EPA. No finer proof of this exists than the fact that there was not a single major industry recommendation made to the EPA at the public hearings on the proposed asbestos emission regulations that was not accepted either in toto or in principle f in the final standards, which were published in early April of this year. - We are presently working with the EPA on the development of waste water effluent standards for asbestos manufacturing plants. We certainly hope that these standards will turn out to be as reasonable as the air pollution regulations. The proposed effluent standards are scheduled to be published in the Federal Register sometime this Summer, to be followed by public hearings, with the final standards being promulgated in the Fall, perhaps as early as October. We are also planning, in the near future, to meet in Washington with representatives from the standards development and enforcement branches of the EPA to discuss with them questions of interpretation and compliance policy with regard to the new air pollution regulations. A 19 50 .) UCC 010514 25 We have already resolved one interpretation question that is of special interest to the asbestos textile industry. Approximately two weeks ago I was asked by a member company of the Association to find out whether the EPA was planning to require the manufacturers of asbestos safety clothing to register as potential emission sources under the law. In discussing the situation over the phone with EPA compliance officials, I argued that the producers of asbestos safety clothing were not manufacturers as defined in the regulations but were instead only fabricators of an asbestos product, and as such, should not have to register as potential! emission sources. After our phone conversation ended, a brief meeting was held among the EPA compliance people. I was then called back and informed that they agreed with me that the safety clothing producers should not be required to register. While this rather minor problem took approximately an hour and a half and two or three phone calls to resolve, it is indicative of the type of day-to-day services that the Association provides for its member companies. Over the past year the Food and Drug Administration has shown an increasing interest in asbestos as a possible hazardous contaminant in various foods, beverages and drugs. Late in 1972 they set up an asbestos task force to review the situation and to propose regulations and guidelines where appropriate. ft ' C C ' UGC 010515 26 Thus far they have concentrated their efforts in two areas ------ on the use of asbestos-contaminated talc in food packaging and in cosmetics, and secondly, on the use of asbestos eelulose filter pads in the beverage and drug industries. In our first meeting with the FDA task force last November on the filter problem, they demonstrated and admitted to an appalling ignorance about the health hazards of asbestos. Since then, they have gotten one heck of a lot smarter, due at least in part to the tremendous amount of data and information which the Association has been supplying to them. As a consequence, the FDA is today less panicky about asbestos and therefore leJs likely to propose foolish, unsupportable regulations. Spokesmen from the FDA have, in fact, defended the filter industry against environmentalist attacks in the press and elsewhere 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's compensation reform, at which time asbestos is unquestionably going to be racked over the coals by Dr. Selikoff and by representatives of organized labor. Unfortunately, the Association has neither the manpower nor the time to embark on a full-scale legislative information program. We have met on occasion with the legislative and UCC 010516 A I9 60 A i 27 legal assistants to various Senators who have attacked asbestos, however much more needs to be done in this area and I am afraid individual member companies are going to have to be the prime ball carriers and not the Association. For essentially the same 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 control has been usurped by various Federal regulatory agencies. Nonetheless, more individual company activity is required at these levels of government. f In conclusion, I think we 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 workmen better protected. The general public has been shown to be in no danger from asbestos, if it ever was. While we have been regulated extensively, for the most part the standards that have been developed have not been as bad as we feared they might be, and in some cases they turned out far better than we ever dared hope. In addition, while we are still taking our lumps in the public press, the net effect of all this adverse publicity has been shown to be surprisingly small. A 19602 UCC 010517 28 ' We have sweated a lot and we have groaned a lot, but we are still standing and we are still viable. I sense today within the industry a greater feeling of confidence in the future than at any time in the past few years. But we must not rest contented. We must remember that Dr. Selikoff has to date been far less successful than our industry has in influencing the decisions of the various governmental regulatory agencies. This will make him try harder. Just last week I saw a speech of his in which he misinterpreted some data by a distinguished British scientist so as to "prove" that even two fibers is not a sufficiently safe level for occupational exposure to asbestos. The struggle is far from over. We must not only continue but indeed expand our activities in the various areas of concern if we are to assure the future well-being of the asbestos industry in the United States. UCC 010518 A i 9603