Document Vj4BqgMpvgzEg4Dgpa0kJVa44

America's occupations! health effo il i t. r T\ IT rT f~-'> $ ZS '['/ !'>'' s thr-. V'v< e W fc-i V* b C.5 ^^ ^ ? v 3 Cu> 04 i . J'jWoj -a^. '-^ 4 \\ iJ Dr. Thomas F. Mancuso Graduate School of Public Health University of Pittsburgh Dr. Irving J. Selikoff Environmental Sciences Lab. Mt. Sinai School of Medicine Dr. Samuel S. Epstein School of Medicine Case Western Reserve University i I "Three years after the implemen tation of the Occupational Safety and Health Act, many of us who were grateful for its passage, sadly and reluctantly must conclude that its promise is not being fulfilled and that its major goal--the control of occupational disease--is not being met." With this statement delivered in oversight hearings on OSHA before the House Select Subcommittee on Labor, Dr. Irving J. Selikoff began his scathingly critical testimony of industry's and government's neglect of the occupational health of Amer ica's workers. Prominent among those who joined Dr. Selikoff were Drs. Thomas F. Mancuso and Samuel S. Epstein. Together, their state ments paint a harsh picture of past failures in occupational health con tinuing uncorrected despite the pass age of the OSH Act. Their interna tional eminence in medical science gave force to their testimony. Dr. Selikoff is professor of medi cine and community medicine and director of the Environmental Sci ences Laboratory at Mt. Sinai School of Medicine. He received the Albert Lasker Award from the American Public Health Association for his research into tuberculosis. He has also won acclaim for his research on asbestos-related cancers. Dr. Mancuso is research professor of occupational health at the Gradu ate School of Public Health, Univer sity of Pittsburgh. He was formerly head of Ohio's Division of Indus trial Hygiene for 17 years. Mancuso has pioneered in techniques of epi demiological research dealing with the long-term effects of low-level ex posures to toxic chemicals. He has attained recognition for his research on occupational berylliosis and health hazards in the rubber and chromates industries. Dr. Epstein is professor of en vironmental health and human ecol ogy at Case Western Reserve Uni versity School of Medicine. He holds six medical degrees and diplomas and his list of published books and articles, society memberships, ap pointments to government research and advisory committees, and consultantships to major associations and labor unions runs 23 single spaced typewritten pages. In their testimony before the House subcommittee, the three scien tists criticized the National Institute for Occupational Safety and Health (NIOSH) for the paucity of its rc- Contirwed on page 96 94 OCCUPATIONAL HAZARDS/Seplember 1974 T 100 > g 2 Commitment lacking, condition critical? ------ '"73 u_ * I V w 'w.*' 'it-' Dr. Robert M. Clyne Corporate Medical Director American Cyanamid Co. Dr. Ellington M. Beavers Senior Vice President Rohm and Haas Co. Dr. Miles O. Colwell Vice President, Health and Environment, Alcoa When Drs. Irving J. Selikoff, Thomas F. Mancuso, and Samuel S. Epstein appeared before the House Select Subcommittee on Labor dur ing recent OSHA oversight hear ings. they charged that occupational health in America is critically ailing due to the neglect of OSHA, NTOSH, Congress, and industry. Afterwards, Occupational Haz ards sought out a panel of leading industrial hygienists and medical di rectors for their reaction to the testi mony. Our respondents included: William E. McCormick, managing director of the American Industrial Hygiene Association (AIHA); Dr. Robert M. Clyne, corporate medical director of American Cyanamid Co.; Dr. Ellington M. Beavers, senior vice president of Rohm and Haas Co.; and Dr. Miles O. Colwell, vice pres, health/environment, Alcoa. We asked our panelists to com ment on Dr. Selikoffs observation that the promise of the law "is not being fulfilled and that its major goal--the control of occupational disease--is not being met." Dr. Robert M. Clyne, of Ameri can Cyanamid Co., agrees with Seli koff. "Due to underfunding, OSHA is far from meeting its occupational health goals," Dr. Clyne told OH. "Its main problem is, simply, a lack of personnel. "I think it's foolhardy for Con gress to enact a law and then not give it enough money to achieve its objectives," Dr. Clyne said. "If la bor, academia, and management are going to work together to improve the health of workers, we need the resources to do it. We need more and better inspections, on-site con sultations, and a clear interpreta tion of OSHA's various require ments. My company recently had to hold up construction of labora tories for 4 months while we waited for a definitive interpretation of OSHA's carcinogen standard." William E. McCormick, manag ing director of AIHA, said his big gest gripe with OSHA is that it has no qualified industrial hygienists in top level, decision-making positions. "Now that OSHA is developing new health standards, it's playing a new ballgame and needs qualified health personnel in its highest echelons. "Instead, we find in OSHA a lack of appreciation for the health profes sional," he charged. "The industrial hygienists OSHA does have aren't being used to the best advantage. It seems the policy there is to stop training people after they're hired, Continued on page 97 September 1974/OCCUPATIONAl HAZARDS 95 ? Q Q L t3 Z Conh'au^ from page 95 "/ and mv fellow professionals in occupational health are dedicated to. helping all working people.. But. if we follow all the recommendations of our critics, ice will emasculate the industrial vitality of this country thereby stunting their professional growth. Compliance officers are a good example. They get little addi tional health training." Dr. Ellington M. Beavers, of Rohm and Haas, disagrees. He says that OSHA has done a very credit able job. "It was created in a com plete vacuum," he told us. "OSHA had to put together a staff at a time when the competition for safety and health professionals was keen. If I had created what OSHA has thus far, I'd be damn proud." Alcoa's Dr. Miles O. Colwell echoes his colleague's opinion. "OSHA is a new organization that has come a long way," he said. "Granted, it hasn't completely con trolled occupational disease,. but neither has anyone else." Lack of standards Dr. Clyne cited what he believes to be OSHA's major failure in oc cupational health. "It's almost 4 years after the law was signed and more than 3 years after it was im plemented, and we have only three health standards--on asbestos, vinyl chloride, and the carcinogens. Now OSHA and NIOSH plan to write 400 health standards over the next several months. This should have been done years ago. Industry wants to know what the game is and what the rules are." Assessing the health standards OSHA has promulgated. Dr. Clyne said: "The asbestos standard is real istic and practical. However, the proposed vinyl chloride standard, which would limit exposure to `no detectable level,' doesn't make much sense. To try to promulgate a stand ard that will wipe out an industry is foolhardy. Also, the documenta tion for the effects of low-level ex posure to vinyl chloride just doesn't exist. OSHA is extrapolating from animal studies to humans." Dr. Beavers believes OSH. should conduct more extensive search before setting low exposun limits. "A casual bystander or criti might say: `Why not legislate a no exposure level immediately?' That would please a few academicians, but it would also eliminate many jobs. Such decisions have to be based on facts, and to get the facts takes time," Dr. Beavers said. Our respondents agreed unani mously that NIOSH is floundering "NIOSH's failure thus far has beer more a lack of funding than a lacl of desire," said Dr. Colwell. Dr. Beavers agreed, and added "One of NIOSH's problems is a con stant flow of people through the or ganization. Because of this high turnover, NIOSH loses the benefit of1 accumulated experience." AIHA's McCormick took NIOSH to task for its criteria documents. "OSHA's slow pace in promulgating occupational health standards is due in part, 1 believe, to the way criteria documents are developed," he said. "NIOSH has prepared many of them like scholarly, academic tomes which have little practical value. The heat stress document is a good ex ample. It's no wonder OSHA balks at them, thus creating friction be tween the two agencies." Dr. Colwell told us that NTOSH has been "overly cautious in select ing data as bases for recommended health standards. It tends to pick out the most restrictive data as bases, whether those data have bee," ; validated or not. Hidden hazards B. F. Goodrich stirred up a storm when it announced it had discov ered three cases of angiosarcoma, a rare form of liver cancer, among employees at its Louisville, Ky. vinyl chloride operations. In the aftermath, some occupational health ac tivists are blaming industry's health policymakers for having permitted use of the substance. Dr. Beavers said that no one should be blamed. "In most occupa tional hazards that lead to a carci noma, there is a subtle reaction period in which you don't know what can happen," he said. "The fact that you later discover a hazard doesn't necessitate blame. "I think B. F. Goodrich handled the whole thing well," he added. "Remember, the company didn't sweep its discovery under the rug." American Cyanamid's Dr. Clyne lashed out at the critics. "Every body now has 20-20 hindsight about the vinyl chloride crisis," he said. "Drs. Mancuso, Epstein,' and Selikoff. and other critics, all had the opportunity to bellow about this back in 1970. They had the same studies that we in industry had. Re grettably, though, they've chosen in stead to take a hindsight position." We asked Clyne if he agreed with the health professionals who are say ing the 27 vinyl chloride-related deaths discovered thus far are only the tip of the iceberg. "It's possible there may be more cases of angiosarcoma," he an swered. "But I don't think it's quite the overwhelming problem it's been built up to be. There is little doubt that many years ago some workers were exposed to very high levels of vinyl chloride. Since then, however, industry has reduced exposure to vinyl chloride, in many instances to levels as low as 50 ppm. There may be more cases of angiosarcoma, but these will be people who were overexposed in the past. After we reach that peak, we will then notice a rapid decline in occupationallyinduced angiosarcoma." AIHA's McCormick said the im plications of the vinyl chloride issue must be addressed practically. "Can Continued on poge 99 September 1 974/OCCUPATIONAl HAZARDS 97 TT 0 0 Lz *} Z Continued from poge 96 "Three years after implementation, of the OSH Act, many of us who were grateful for its passage reluctantly must conclude that its promise is not being fulfilled "These failures of NIOSH [to re search and to train] are mirrored in the equally unhappy failure of OSHA to initiate surveillance of hazards known to be present among millions of workers," Dr. Selikoff told the subcommittee. OSHA attacked Dr. Selikoff pointed to the as bestos standard an an example. He explained that the asbestos stand ard required employers to make at least one dust count within the first 6 months after promulgation of the standard. After the first 6 months had elapsed, Selikoff surveyed as bestos workers in all 50 States and found that of the 6,000 respondents only 3 percent had seen a dust count. "Despite the Act, despite the Sec retary, despite the standard, despite rules- and regulations, surveillance was absent," said Dr. Selikoff. Dr. Mancuso called on OSHA to require employers to report surveil lance of industry health hazards. "If reliance is based solely on the occasional inspection of the occa sional plant by the government as a means to determine whether oc cupational monitoring has been done, then, in effect, national en forcement becomes an illusion," said Dr. Mancuso. In his testimony, Dr. Epstein launched a frontal attack on OSHA health standards and standards set ting procedures. He complained of "massive disparities" between strict er exposure levels set for the gen eral public in environmental health standards and the more lenient ex posure levels set in occupational health standards. In particular, he decried the fact that safety margins built into the environmental stand ards were missing from occupational health standards. Dr. Epstein also called for the pre-testing of industry chemicals for their health effects before introduc tion into the workplace. "In the ab sence of pre-testing, the worker is unwittingly used as an involuntary test subject. Human experimenta tion of this kind is unnecessary and amoral and our tacit participation in it a matter for shame," Dr. Ep stein said. Dr. Epstein also scolded OSHA for its slow response to NIOSH criteria documents. He said that as of the date of his testimony, NIOSH had forwarded 15 docu ments to OSHA, but OSHA had acted on only one of them. "Such delays have been varyingly interpreted as deliberate attempts to inhibit the promulgation of new standards, due to direct or indirect industrial pressure and lobbying, or as reflections of budgetary, person nel, or grade limitations.' Dr. Epstein also complained that OSHA failed to support the stand ards advisory committees. He said that when he sat on the Advisory Committee on Carcinogens, OSHA did not help the committee subpoena necessary data from industry. He accused OSHA of ignoring the Ad visory Committee recommended standard and promulgating an "emasculated standard" instead. Industry failures Dr. Epstein disapproves of the threshold limit values of the Ameri can Conference of Governmental In dustrial Hygienists which form the bulk of OSHA's current health standards. He attacked them as writ ten by "industry-indentured profes sionals" and as reflecting "narrowly focused trade origins." He said most TLV's are aimed at controlling acute and subacute exposures and "ignore or minimize delayed long term toxic effects, such as cancer, hypertension, and cirrhosis. "The bases for these standards range from poorly educated guesses to well documented studies," Epstein told the subcomittec. Dr. Mancuso claimed that despite OSHA, most of industry was un aware of the scope and frequency of occupational disease and, as a result, their medical programs were sub standard. "The basic question I am raising is whether industry is really aw'are of what is technically required in the standards adopted, in evaluating the work environment, in instituting the necessary control measures, and in provisions of industrial medical service. It is highly probable that compliance has been underestimated in every industry," Dr. Mancuso said. Drs. Mancuso and Selikoff op pose proposals to exempt small busi nesses from OSHA coverage. "In small plants, the levels of ex posures to toxic chemicals, dusts, fumes, mists, and gases are greater, and the health risks to the workers higher because of the closeness of the work processes, the lack of ade quate industrial ventilation or en closure of hazardous operations, and lack of proper control measures," said Dr. Mancuso. "I suggest that the health and safety of its workers not be the item sacrificed to ease its [the small com pany's] difficulties," said Dr. Seli koff. "It is the disease potential of the agent and hazard of the opera tion that will determine if a worker will lose his life--not the size of the business operation." Receptive audience When the three scientists finished their testimony it was clear that the House subcommittee had listened attentively. "Congress should make it its busi ness to see that the administrate n asks enough money to keep NIOSH and OSHA functioning as they should," said subcommittee chair man Dominic Daniels (D-N. Jj"There is no question but that the testimony we've heard re-em phasizes the need for Congress net only to pass laws, but to maintain its oversight functions," said sub committee minority leader Marvin Esch (R-Mich.). B 98 OCCUPATIONAL HAZARDS/September 1974 T 1 " ta rn / "NO!" Conf/nued from pog 97 industrial hygienists remove all the risks from all industrial operations? They obviously can't. To suggest it is like asking that auto accidents be eradicated by having everyone take up walking again. "As long as this is an industrial society, there will be some risks," McCormick said. "Some critics hint that health professionals in industry close their eyes to those risks, don't do everything in their power to con trol the risks, simply because they acknowledge that risks exist and try to control them, rather than eliminate them. To suit their theory, those critics choose to ignore all the con siderable achievements of health professionals in American industry." Pretesting controversy In his testimony during the recent House oversight hearings on the OSH Act, Dr. Samuel Epstein charged industry doesn't pretest chemicals sufficiently for health ef fects before introducing them in the workplace. "Human experimenta tion of this kind is unnecessary and amoral," Dr. Epstein stated, "and our tacit participation in it a matter for shame." In response. Dr. Clyne asserted that it's impossible to pretest all sub stances. "Consider the number of substances being used," he said. "MOSH lists 25,000 toxic sub stances, including table salt. Many of these have been used for years without adverse effects. We can as sume many of them are safe. "To require experimentation with all substances would cripple prog ress in this country," Dr. Clyne con tinued. "Complicated and prolonged testing of substances would mean sacrificing comforts and luxuries we've long taken for granted. I think society is going to have to make a choice between prolonged testing or continued progress." Alcoa's Dr. Colwell added: "There must be some sound basis for the decision to pretest or not. It's definitely unnecessary and im practical to test every chemical used in the workplace." AlHA's McCormick cited the un predictability of many chemicals-. "When any new chemical comes out. we do perform some testing on an imals," he said. "If we discover the risk is unacceptable, we abandon the material. "But, as we found in vinyl chlor ide, there might be some undiscov ered hazard that won't show up for years. I don't know how you'd avoid it. Even with better testing, we'd never be- 100-percent sure." We asked McCormick if the American Industrial Hygiene Asso ciation supports the Toxic Sub stances Control Act, now in Con gressional conference committee, which would require pretesting of all hazardous and new chemicals used in industry. "AIHA has taken no position on the Toxic Substances Control Act," he answered. "I am familiar with product testing from my days at B. F. Goodrich. I know testing is very valuable, but I think it's a bit too much for the government to re quire testing for every single sub stance. Even if the government were to require it, some hazards would slip through. After all, when B. F. Goodrich introduced polyvinyl chloride in 1940 or 1941, the Food and Drug Administration was sat isfied that it was safe for contact with food. The FDA granted an approval still unrescinded." Rohm and Haas' Dr. Beavers thinks Federal regulation isn't nec essary. "We in industry have be come even more aware of the hid den, potential hazards in chemicals," he told us. "We are developing bet ter in-house toxicological labora tories, and more and better tests to be conducted long before the chem icals reach use in manufacturing. "My own company is very con scientious and careful about the chemicals we use in the manufac turing process," Dr. Beavers con tinued, "and I don't think we are an exception in that regard. "I hope the law isn't passed. But one area in which government reg ulation might be required is for small companies, which can't afford a toxicological laboratory. We have to provide them some help, and perhaps the government can do it best," he said. Industry-indentured? We asked Dr. Beavers how he would answer Dr. Epstein's charge -that, the .threshold limit values- - . (TLV's) adopted by OSHA were developed by "industry-indentured" professionals in the American Con ference of Governmental Industrial Hygienists (ACGIH). "I would laugh," Dr. Beavers said, and did so briefly. "Dr. Ep stein is a genius with flamboyant language. I think he's intentionally overstating his case in order to .achieve some end. "His charge is without founda tion. The chairman of ACGIH is upright and reputable," he said. AlHA's McCormick agreed, and added: "Dr. Epstein is either un familiar with ACGIH TLV's or un familiar with the way they're estab lished. There are no industry people in ACGIH--it's composed of gov ernment professionals. Industry people may be called upon to make comments, but the group that makes the decisions on TLV's are exclu- ' sively government employees. "What's more," McCormick said, "the ACGIH TLV's are highly re garded internationally and are used in many industrial countries." "True professionals" Our respondents said they are familiar with the assumption held in some quarters that any health professional who works for industry is therefore industry-indentured. Dr. Colwell thinks it's a bum rap. "I have respect for professionals, no matter where they come from. True professionals use their best judg ment and won't let their work origin influence them." Said Dr. Clyne, "It's a fallacy to say that a TLV or anything else that comes from industry is, there fore, a management tool. What amazes me is how Dr. Epstein and other critics constantly shoot at in dustry, but don't admit that much of the progress in occupational health has been discovered, researched, and put into use by industry. "I and my fellow professionals inoccupational health are dedicated to helping all working people," Dr. Clyne said. "But if we follow all the recommendations of our critics, we are going to emasculate the indus trial vitality of the United States." September 1974/OCCUPATIONAl HAZARDS 99 23627005 . T T " The VC standard: The arguments are in, OSHA's decision is imminent by Carl P. Musacchio Is there a safe exposure limit for vinyl chloride? On that question could hang the fate of an entire in dustry, thousands of jobs, and bil lions of dollars in sales and profits. OSHA's proposed standard for exposure to vinyl chloride (VC) holds that there is no safe limit. It calls for no measurable concentra tion of VC in the workplace--in other words a threshold limit value of zero. Spokesman from industry prophesy that adoption of this stand ard would end production of VC and, in so doing, have devastating effects on the plastics industry. The drama began last January when B. F. Goodrich Chemical Co. announced that several deaths from angiosarcoma of the liver, an ex tremely rare cancer, had occurred among workers in vinyl chloride op erations at the company's Louisville plant. Goodrich Chemical called in Ken tucky public health officials and the National Institute for Occupational Safety and Health. After an initial investigation Dr. Marcus Key, direc tor of NIOSH, made a momentous announcement: "On the basis of the medical, epidemiologic, and tox icologic findings thus far, it would appear that a new occupational can cer has been discovered: angiosar coma of the liver. It is associated with the polymerization of vinyl chloride in the manufacture of poly vinyl chloride. Vinyl chloride is the chief suspect among the more than 50 chemicals used in the plant." That announcement hit the indus try like an iceberg scraping the hull of a luxury liner. Without question an emergency was at hand, but as long as the watertight compartments held, there was no cause for panic. The deaths were, after all, in one plant, and they involved only the polymerization process which con verts vinyl chloride monomer, a gas, into solid granules of polyvinyl chloride resin. Synthesis of VC monomer and the polymerization process involved only a small seg ment of the industry. Fabrication of PVC resins into myriad products, ranging from auto seat covers to insulated electrical wire, involved far more workers and was the eco nomic mainspring of the industry. As the Manufacturing Chemists Association pointed out: "It is esti mated that about 1,500 workers are employed in monomer synthesis, and an additional 5,000 in polymeriza tion operations. It is difficult to estimate the number of workers en gaged in converting, molding, and fabricating these polymers, but they are numbered in the tens of thou sands, working in thousands of plants. It has been estimated the wholesale value of the annual out put of fabricated products is over S3 billion." Cancer spreads Within weeks of the first an nouncement it became clear that the cancer was not confined to one operation in one plant. Cases of an giosarcoma were discovered among workers in synthesis and polymer ization plants in several States and in Europe. In early May, the vast vinyl fab ricating industry was implicated. A group of German scientists reported to a conference' on vinyl chloride hazards sponsored by the New York Academy of Sciences, the American Cancer Society, and NIOSH that six cases of serious liver disease had been discovered in a German plant manufacturing vinyl floor tiles. None of the afflicted employees had cancer, but the scientists believed the symptoms might have been those of incipient cancer. Again, VC monomer was suspect. The inves tigators guessed some VC monomer had eluded the polymerization proc ess, and had become trapped in the PVC resins. Over the years then, the workers had been exposed to VC monomer escaping from the resins. A month later, the Connecticut Department of Health reported two deaths from angiosarcoma. Both victims had worked in plants making finished products from PVC. One had worked at coating electrical wire with vinyl. The second was an ac countant for a firm that fabricated products of PVC. An investigation was launched to learn if he had ever worked in the plant. Most ominous of all was a report from Connecticut that two cases of angiosarcoma might have resulted from environmental, not occupation- Seplember 1974/OCCUPATIONAL HAZARDS 101 T 1" 4 al exposure. One victim was a man the skin, lungs, and bones. Later i who lived about a mile from a PVC tests by Dr. Cesare Maltoni, of th product fabricating plant. The other, Institute of Oncology (the stud', a housewife, lived even farther from tumors), Bologna, Italy, had pro a similar facility. duced tumors of the kidney and Now every phase of the industry liver at concentrations of 500 and had been involved, and some were 250 ppm. calling to abandon ship. In April, Peter Bommarito, president of the The MCA knew of the work of Drs. Viola and Maltoni. MCA\ United Rubber Workers, had Chemical Safety Data Sheet on VC warned: "I feel this is a figurative referred to the Italian carcinoccni- i and literal life-and-death struggle city studies in its 1972 edition. for the polyvinyl chloride resin in Meanwhile, MCA had arranged for dustry in the world." In June, after 17 U.S. companies to sponsor re the dimensions of the outbreak had search and animal studies based on become clearer, Bommarito added: the findings of Maltoni and Viola. j "If PVC cannot be made and used safely, then the proposed OSHA standard must be replaced by an or Zero exposure "There isn't any likelihood . . . that we are going to put derly procedure to phase out VC production and find substitutes for its products, or to phase out the products themselves." Out of business? In the furor that followed the VC disclosures, OSHA felt pressure, notably from the United Rubber Workers, Oil Chemical and Atomic Workers Union, and the AFL/CIO to issue a temporary emergency the industry out of Little wonder that some spokes standard on VC. business." men for the plastics industry be On April 5, OSHA issued an Dr. Daniel P. Boyd Director, OSHA Office of Standards Development lieve that phaseout of VC and PVC is a real, though unjustified, possi bility. They see the proposed OSHA standard for worker exposure to VC as the specific threat. Through emergency standard that limited ex posure to VC to 50 ppm and that established monitoring and record keeping requirements. The OSH Act limits the life of temporary their major trade associations, es emergency standards to 6 months. pecially the Society for the Plastics This one, then expires on October 5. Industry (SPI) and Manufacturing When the emergency standard Chemists Association (MCA), man was promulgated, the only generally i ufacturers and users hammered known experiments on the carcino across their message in 9 days of genicity of VC were those of Dr. OSHA hearings on the proposed Maltoni and Dr. Viola. Neither had standard. Apparently with some effect. No observed cancers in laboratory an imals exposed to 50 ppm. But final standard was announced by shortly after announcement of the I presstime, but OSHA's top stand 50-ppm emergency standard, pre i ards officials were talking of a com liminary test results became avail promise the industry could live with. able from one of the research proj The issue in the VC standard is ects MCA had sponsored as a result one that's been fought over before: Should the TLV for a carcinogen, proved or suspect, be set at zero, of the Italian studies. Industrial BioTest Laboratories of Northbrook. 111., the MCA contractor on the proj or is there an acceptable maximum ect, revealed that mice exposed to dose, a threshold limit value, below which no adverse reactions can be 50 ppm for 7 hours a day, 5 days a week, for 7 months, had developed expected? angiosarcomas. "The effect [of the proposed standard] on Before the cancer scare, the TLV for VC was set at 500 parts per mil lion (ppm), though as eariy as 1970 The industry knew then, that OSHA's proposed permanent stand ard, unlike the temporary emergency i the nation's economy would be catastrophic." Ralph L. Harding European researchers were report ing some disquieting data about the effects of that concentration on lab oratory animals. Dr. P. L. Viola, standard, would come in below 50 ppm, but most PVC manufacturers and users were stunned when the proposed permanent standard was President, of the Regina Elena Institute for issued. It called for limiting occupa 3 Society for the Cancer Research, Rome, reported tional exposure to vinyl chloride to Plastics Industry rats exposed to vinyl chloride at "no detectable level," as determined 1M 30,000 ppm developed cancers of by sampling and analytical methods 102 OCCUPATIONAL HAZARDS/Seplember 1974 f <\C\ / - y r t T I it iij ''' \ i- . i*- t t *> \ 'i LV I 1 ( ->-------J- - -^twL^t it l: i II ,| 5 t --* I &ir 'rill I~,. >*- iie-al^WSi klMi tMit capable of detecting VC in concen trations of 1 ppm, with an accuracy of 1 ppm plus-or-minus 50 percent. The proposal applies to any area or operation in which vinyl chloride is manufactured, reacted, released, repackaged, stored, or used. Thus, the standard would cover PVC fab ricating operations if the PVC resin being used is releasing detectable amounts of VC monomer. The standard specifies monitoring to as sure that any exposure for any em ployee can be determined. It or ders feasible engineering controls to hold concentrations below the de tectable level. Self-contained respi rators are to be used where concen trations can't be kept down. Challenge and response In their response to the proposed standard, industry representatives lined up to testify that: There is no scientific evidence establishing the need for a zero TLV. Enforcement of the standard would destroy the industry. Current control technology cannot achieve the concentration levels ordered by the standard. Questioning the need for the nodetectable-level standard, Dr. Carl U. Dernehl, associate medical direc tor for Union Carbide, offered re sults of a survey of employees in 36 VC producing plants. `The tests have failed to show the existence of abnormal liver func tion in greater proportion than would be found in a control popula tion," he said. The test involved 1,402 men, all of whom had been exposed to concentrations of 50 ppm or higher, and all of whom had been exposed long enough to develop the disease. "Yet, there was not a single case of angiosarcoma," Dern ehl said. Enforcement of the standard could mean a loss of production and sales of between $65 and $90 billion according to a study by A. D. Little, Inc. contracted by SPI. Not only the plastics industry, but autos, construction, communica tions, toys, shoes, luggage, and many others would be hit hard, the study's authors concluded. SPI president Ralph L. Harding said, "The effect [of the proposed permanent standard] on the nation's economy and on the social order in terms of human hardship it would cause would be catastrophic. We ex pect the final results from A. D. Little will show a potential loss in excess of 2 million jobs. This is all the more regrettable in light of the fact that the industry is taking every possible step to reduce worker ex posure to VC monomer." 2 3 6 2 7 0 OS September 1974/OCCUPATIONAl HAZARDS 103 TI Rather than the controversial pro posed standard which lumps to gether both producers and users, Anton Vittone, president of B. F. Goodrich Chemical, speaking for SPI, asked for separate standards for PVC resin producers and VC synthesizers. The standard for resin producers should require: Effective October 5, 1974, a ceiling of 40 ppm with a maximum daily time-weighted average (expos ure averaged out for an 8-hour workday) of 25 ppm. Levels above 40 ppm would require use of prac tical and effective respiratory pro tection. Effective October 5, 1975, a ceiling of 25 ppm with no timeweighted average. Levels above 25 ppm would require use of practical and effective respiratory protection. For plants that synthesize vinyl chloride monomer, Vittone's sug gested standard would require: Effective October 5, 1974, a ceiling of 25 ppm and a maximum time-weighted average of 10 ppm. Levels above 25 ppm would require the use of practical and effective respiratory protection. Effective October 5, 1975, a ceiling of 10 ppm and a maximum time-weighted average of 5 ppm. Levels above 10 ppm would require the use of practical and effective respiratory protection. Vittone noted, "It is the position of industry that it will commit itself to lowering exposure of its workers by a combination of lower levels of vinyl chloride in the work atmos phere and work practices. [This] proposal makes projections for im provement which are not in hand but depend on new developments and additions to facilities." . The SPI proposal, according to Vittone, would require substantial outlays and could take more time than estimated. The standard should, Vittone maintains, permit companies to apply for variances. Vittone also maintains that the no-detectable-level standard being considered by OSHA would require full-time use of self-contained breathing apparatus during the workday for many employees. "This would impose a severe and unneces sary physical burden on workers and create potential health and safe- "This is a . . . lifeand-death struggle for the [PVC] industry in the world . . Peter Bommarito President, United Rubber Workers ty problems as well," he said. William Miller, manager of cor porate safety and workmen's com pensation, Goodyear Tire and Rub ber Co., recommended not two but three standards, one each for the producers of VC monomer, the pro ducers of PVC resin, and the fabri cators and processors of PVC resins. "Goodyear fails to see how OSHA can scientifically conclude that ex posure to VC at concentrations of 50 ppm can constitute a serious health hazard to humans," Miller told OSHA. What's possible? John L. Nelson, vice president of manufacturing for B. F. Goodrich Chemical Co., offered evidence on the level of contamination his firm has been able to meet. "Hundreds of readings per day taken at several plants show considerable progress in reducing levels of exposure," he said. "The average reading was re duced from about 35 to 40 ppm early this year, to about 12 to 14 ppm at present. Readings range "It is the position of industry that it will commit itself to lowering exposure . . Antone Vitton President, B.F. Goodrich Chemical from 1 to 2 ppm as a general level with occasional excursions over 50 ppm. A summary of time-weighted average exposures by job classifica tion showed considerable variation in time-weighted measurements, ranging from below 5 ppm to 31 ppm on polymerizer charging opera tions." Nelson also noted that re duction of leaks had done the most for reducing general levels of VC in Goodrich Chemical plants. Firestone Plastics Co., about the only major producer to disagree with the SPI proposal of a step-by-step reduction in the TLV, called for a standard that would limit exposure to 40 ppm with a time-weighted av erage of 25 ppm. T. C. Walker, president of Fire stone Plastics, said, "Clearly, the human deaths caused by admittedly high levels of VCM exposure not now permitted in Firestone's plants or industry generally, suggest nothing with respect to the effects on humans of the low levels of VCM presently permitted in Fire stone's plants and industry gener ally." If compelled to comply with 104 OCCUPATIONAL HAZARDS/September 1974 'T a standard of no-detectable concen tration, Walker concluded that Fire stone would have to cease VCM op erations. Studies made by engineer ing consultants i n.d i c a t e,. Fjrestone would fiave to spend from $50 to S55 million to meet the proposed OSHA standard. Even a 50 ppm level would require about $10 mil lion in engineering controls alone. Dow Chemical Co.'s testimony at hearings on the proposed standard caused a stir that may have under cut other industry testimony. Dow announced it has achieved a nodetectable level of VC monomer on some operations. On the average, the company has held levels down to 10 ppm on an 8-hour timeweighted average. This level has been achieved for most operations, though occasional malfunctions or emergencies cause briefly higher concentrations. Dow's medical records show workers exposed to VC had a ma lignancy rate no different from what would be expected in a comparable group which had never been ex posed. Records show no deaths due to angiosarcoma or any other type of liver cancer. Common ground? "There isn't any likelihood in my mind that we're going to put the in dustry out of business," remarked Daniel P. Boyd, director of OSHA's Office of Standards Development after hearing testimony on the pro posed standard. Boyd doesn't ex pect the final standard to require industry to achieve a no-detectable level of VC monomer in the work place. "Evidence at the hearings in dicates a standard of 25 parts per million can be met across the indus try. The final standard will prob ably be somewhere between zero and 25 ppm," he said. In any event, the final standard won't be issued until OSHA has completed a study of the technolog ical and economic feasibility of vari ous levels of exposure. "Now that we have the drift of the hearings of VC, we are able to focus on the cost-benefit elements which must be part of our decision making proc ess," Boyd said. One argument the Department of Labor has apparently not bought is that compliance with the proposed standard would shut down the in "Goodyear fails to see how OSHA can scientifically ' conclude that exposure to VC at concentrations of 50 " ^ ppm can constitute a serious health hazard to humans." ' dustry. The Department of Labor's draft environmental impact state ment on the standard acknowledges that some marginal firms might be hurt, but adds that demand for PVC is so strong, it would probably re main relatively unresponsive to price increases made necessary by the cost of compliance with the standard. In any case the standard is being reconsidered, and, as far as the De partment of Labor is concerned, the zero concentration requirement seems to be out of the running. Most insiders think a limit of 10 ppm, however, is a distinct possi bility for the permanent standard. Labor views "It will be a tragedy if OSHA adopts a common denominator standard that everybody can meet so that those plants that can go further are under no incentive to do anything more. For those plants which cannot meet a no-detectablelevel standard, the variance pro cedures of the OSH Act should be utilized," said Anthony Mazzocchi, citizenship and legislative director of the Oil, Chemical, and Atomic Workers Union. Mazzocchi, like many other union officials in the petrochemical and plastics industries, believes industry's claims that the proposed standard will bankrupt them requires much closer scrutiny than it is getting. He pointed to the Dow Chemical Co. testimony that some plants had achieved the zero TLV in monomer operations. "It is our hope that the proposed permanent standard would force the industry into a proper pre ventive maintenance program which will reduce exposure to VC to the nondetectable level," he said. Peter Bommarito, president of the United Rubber Workers, maintained the industry threats were nothing but blackmail. "This country survived for nearly 200 years without poly vinyl chloride and we can survive in the future without it," Bommarito told the press. With labor leaders playing the role of immovable object, it's clear that any proposal to back away from the no-detectable-level standard will be in for trouble. And the trouble will come not only from the leader ship, but from the rank-and-file membership as well. Angelo Cefalo, special assistant to the president of the International Association of Machinists and Aero space Workers, pointed to growing fears of his union's members who work with PVC. Cefalo said one member told him that he was be ginning to feel that breathing in VC had caused something to grow in his.body that eventually would make him die of cancer. Whoever sets the final standard, then, is going to have to reckon not only with technological and eco nomic feasibility, but with a very normal ailment that many people, including much of the industrial workforce, suffers. It's called carcinophobia and it means a fear of cancer. "It will be a tragedy if OSHA adopts a common denominator standard because those plants that can go further will have no incentive to do so." sn. uU.'W September 1974/OCCUPATIONAL HAZARDS 105 2 3 6 2 7 0 J.0 T T '* BFGoodrich// Q INVESTIGATE AND REPORT Q NOTE AND RETURN TO ME NOTE ANDSEE ME ABOUT THIS Q NOTE AND FILE _______ _________ ___ TELEPHONE PLEASE CALL MR. MRSMISS TIME CALLED TELEPHONE NO. ?7z3/7</ / jirfess/GE FROM: 64* rt, TRANSMITTAL AND TELEPHONE SLIP DEPT. B = <3 -3 9 72 * 8 3/72 Printed in U.S.A. Y o)ous^?tf T1