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October 1974 ON THE HORNS OF THE VINYL CHLORIDE DILEMMA by Paul H. Weaver Reprinted solely for the information of The B.F. Goodrich Company 1974 Time Inc. BFG21032 :37320C1 If government allows workers to be exposed to the gas, some of them may die. If it eliminates all exposure, a valuable industry may disappear. ON THE HORNS OF THE VINYL CHLORIDE DILEMMA by Paul H. Weaver Not Ion."' ago, cancel- and plastic were associated with each other only in the writings of Norman Mailer, where they serve as symbols of decadence and self-destructive ness in the high-technology society. Since -January of this year a series of medical reports has shown this associa tion to be a real scientific fact as well. It is now clear that vinyl chloride, a gas from which the second most widely used U.S. plastic is made, causes a fatal cancer of blood vessel cells in the liver : the gas is also implicated in a host of additional diseases, ranging from gastrointestinal bleeding to chromosome damage. These discoveries have touched off a flurry of regula tory activity. The Food and Drug Administration, the En vironmental Protection Agency, and the Consumer Prod uct Safety Commission have all banned aerosol sprays using vinyl chloride as a propellant. But the measure that cuts deepest was taken by the Occupational Safety and Health Administration. OSHA has moved to reduce the permissible level of worker exposure to vinyl chloride in the plants where it is made or converted into plastic. Preparing for the iceberg In the course of these developments, it has become clear that our regulators have a hard time thinking sensiblv about problems like vinyl chloride. The businessmen be ing regulated and the workers affected seem to find it no easier. The fact is that our society seems to have no. agreed-upon standards for dealing with situations in which medical and economic considerations collide headon. Since collisions of this sort will plainly be numerous in the years ahead--the vinyl chloride case is widely iden tified as the tip of an enormous regulatory iceberg--it seems useful to get clear on the issues involved. If vinyl chloride were an unimportant substance, or if it were known to be dangerous only in very high concen- Research associate: Sydney Ladensohn Stern trations, or if it were easy to keep human beings out of contact with it, there would be no particular problem. In that case the health danger could be completely elimi nated at little or no cost, and the question of what to do would answer itself. Unfortunately, the vinyl chloride issue isn't so simple. It seems to be very difficult and costly--and it may be im possible--to guarantee that no vinyl chloride worker will be exposed to the gas. Though no one knows for sure, it is possible that even very small exposures may cause sick ness or death. Yet it is also true that the plastics made from vinyl chloride are extremely important to the Amer ican economy. The market value of the gas being pro duced this year, and of the resin made from it, is perhap SI.5 billion; the gas and resin industries together emplc. about 6,000 workers. But what most people think of as the "plastics industry"--the transformation of resins in to products--is a far larger operation. The total number of jobs involved in polyvinyl chloride (PYC) alone is about 320,000; the sales volume runs to many billions. And there are no entirely satisfactory substitutes for PVC at hand. Banning it would be certain to cause grave economic dislocations. Thus the regulators at OSHA are caught between the proverbial rock and a hard place. It is clear that their task should be to find the right "trade-offs"--to devise regulations in which the benefit of increased health for The most hazardous job in polyvinyl chloride plants ,,sed to oe toe cleaning of the vats in which ynyl chloride polymerizes into PVC--mat whitish resin at the worker's feet. Of the sixteen known 'J S cases of vmyl-chloride-related liver cancer, fourteen occurred m vat cleaners. The iob is presumably a lot less hazardous since the introduction of 'he respirators, protective clothing, and air evacuation (provided oy the dan gling hose) that are shown here. The stainless-steel-lined vat sncwn is .n B.F. Goodrich s Pedricktown, New Jersey, plant, perhaps the most mod ern m the U.S. The vat is entered and cleaned manually emy once a month. Until recently vats m most older plants were entered once or twice a day. 23732002 Henry Groskmskv BFG27033 j i j I The View from NIOSH: --protective coveralls, shoes, and gloves for workers exposed to PVC. --airtight suits and respirators for but industry and labor had split over the exposure ceiling. Industry urged 50 ppm. which it knew it could i Make It Safe reactor cleaners. achieve; labor advocated "no detect --daily showers for exposed workers, able level," refusing to treat workers --a art parts per million suggested as guinea pigs. On January 22, L'74. Or. Maurice oeiiing on vinyl chloride monomer In this situation, Rose simply Johnson, envir..amenta! health diivc- `c 'sure. toughened and expanded on his ear Normally, writing a criteria doc lier recommendations. Most impor Marcii.- Key, ii:r,..o *h.- National ument-- N'lOSHese for a recommend tant, he derided that the ceiling for Institute of Occupational Snfetv and ed standard -- is an eighteen-month vinyl chloride be set at "no detectable Health. Johnson had a discovery to process involving exhaustive study. level"--the only exposure he knew to report. Three workers in OoodrichN In this instance, however. Rose relied be safe. "It is doubtful." he conceded Louisville polyvinyl chloride plant had on guesswork and precedent. Assum in a memo to Key. "that any plant died from angiosarcoma of the liver ing that vinyl chloride causes cancer can show workroom levels of non- since 11)71. Key summoned his top through inhalation and skin contact, detected." To meet it. respirators aides, who agreed that they had an he modeled his standards on those would have to be worn at all times. emergency on their hands. Two days used earlier by .NIOSH for industrial He wasn't sure this was practical, later a small army led by NIOSH carcinogens. but he was certain it was safe. Standards Development chief Vernon Aiming for a mid-March deadline. On March 11, Dr. Key submitted Rose, invaded the Louisville plant to NIOSH organized a hectic series of XIOSH's recommendation to Assist conduct the first of many "walk meetings and studies. By the end of ant Labor Secretary John Stender. through" inspections. February, its toxicology group had When OSHA proposed its permanent Within a week. Rose's task force been unable to determine the carcino standard two months later, it incor had a list of recommendations for re genicity of VOM below .70 ppm. The porated most of the XIOSH text ver ducing worker exposure to vinyl medical group had suggested a bat batim, including the "no detectable chloride: tery of liver tests for PVC workers. level" provision. The View from Firestone: Make It Practical To Todd C. Walker, the towering, outspoken president of Firestone Plastics, OSHA's proposed standard was as much a crisis as the Goodrich bombshell had been to XIOSH. He was determined to resist the stand ard with "the maximum information" at the OSHA hearings in Washington, D.C., this summer. Walker assembled four task forces --legal, engineering, financial, and medical--to develop a Firestone-rec ommended standard on a crash basis. Four alternatives were to be studied: the interim 70-ppm standard, "nondetectable," and two intermediate levels chosen arbitrarily--10 ppm maximum with a time-weighted aver age i TWA ) of 25 ppm. and a 15-ppm ceiling with a TWA of 10 ppm. For each level the questions were: is it safe and is it feasible? Weeks later, the medical group was unable to say positively that any of tlie levels was unsafe. An epidemio logical study of Firestone's rubber and PVC workers showed no signifi cant differences, suggesting that 50 ppm was not relatively unsafe. Tlie engineering group reported that the nondetectable level was un attainable. It also forwarded a cri tique of OSHA's proposed work prac tices. Protective clothing for all workers was unnecessary, it said, be cause PVC dust is not a carcinogen. VCM gas, which is, could be kept away from the skin only by air-tight suits, which would be "hot, cum bersome, expensive, and dangerous." OSHA's provision for air-supplied respirators for all exposed workers was also ill advised. These would be uncomfortable i "an instrument of torture"', fatiguing, probably haz ardous, and would interfere with work. One portable type weighs twenty-eight pounds and would have to be changed three times an hour. Nonportable respirators could be used, but workers would be attached to air hoses (themselves a workplace hazard) and confined to a radius of less than fifty feet. The financial group reported that capital investment would have to double to attempt reaching a nonde tectable level. The legal staff conclud ed that OSHA's proposed standard was unfeasible and therefore illegal. When it came to deciding what level he would recommend. Walker had a problem. His medical evidence showed the three levels above non detectable to be equally safe. His en gineers said that the feasibility of the lowest of these i 15-ppm ceiling with a 10-ppm TWA) was uncertain, and Walker ruled it out. Left with a choice between the two higher levels, he opted for the 40-ppm ceiling with a 25-ppm TWA to show that Firestone was willing to do more than the mini mum. Thus, with a practicality rem iniscent of XIOSH's decision to rec ommend a level it knew was safe, Firestone ended up recommending a level it knew it could achieve. 23732G03 BFG27035 workers is balanced against the increased cost to the plas tics industry and society as a whole. Unfortunately, this task has remained largely unacknowledged. OSHA probably will end up compromising on the de cree of exposure to the eras it will allow: its decision is apt to be announced this month. But the agency has been under terrific pressure to view the issue before it in ab solutist terms, as if its only !egi`imate concern were the preservation of ab-opp,. security for 'he vinyl plastics industry, or `he achievement of perfect safe".- for vinyl chli>ride workers. For a while, it seemed a foregone conclusion that OSHA itself would opt for perfect safety. On May l1"*, it formally proposed that the new standard for vinyl chlor ide be set at "no detectable level." i.e., that no plant would be allowed to operate so long as any of the gas could be found in the air or in contact with workers. The industry replied, in effect, that any such standard would be techni cally impossible and economically disastrous, and that if OSHA went through with it, the polyvinyl chloride in dustry would be put out of business. OSHA's final decision will affect more than this single industry and its customers. The vinyl chloride issue may be viewed as the first major test case for a new movement in government regulation. The leaders of the movement are three of the newest federal regulatory agencies, all created since 1970: EPA, CPSC, and OSHA. One general idea behind all of these agencies is that business can no longer promiscuously pass on to society all the indirect costs of running a modern economy. As Sheldon \V. Sam uels, health director of the Industrial Union Department of the A.F.L.-C.-I.O.. put it, "The free ride on social costs is at an end. In the plastics industry you're seeing a manifestation of social costs." With jurisdiction over virtually every product and sub stance, these agencies, together with the FDA, are be ginning to use their sweeping powers to reduce the pub lic's risk of chronic disease, especially from industrial products. Some of the agencies are subjecting new sub stances to rigorous pretesting before they are allowed on to the market. And with the vinyl chloride case, they have tackled the first of a long list of basic substances on which our industrial economy is already built. It could put you to sleep During the first decades of its commercial existence, vinyl chloride seemed a most unlikely candidate for the role of heavy in a historic regulatory drama. Put into full-scale U.S. production in 1939, polyvinyl chloride was hailed as a "miracle" material: cheap, stable, fire-resist ant, and able to assume an extraordinary range of soft and hard forms. Its major applications now include coated fabrics (like those used in automobile seat covers), wire insulation, floor tiling, pipe and conduit, phonograph records, and medical supplies, e.g., blood-storage bags. In the beginning the vinyl chloride gas seemed to be virtually harmless. The only apparent dangers were of explosion (at concentrations beginning around PO.Ooo parts per million) and narcosis. In fact, during the 1940's the gas was tried out as a medical anesthetic, but doctors abandoned it when it was found to cause heart arrhythmia. With low prices providing little incentive for conservation, producers paid no particular attention to workplace exposure levels so long as they were safely below the point of tire and explosion. And ye? exposure levels in plan?- producing the gas itself were probably nor very high even in the early years. Vinyl chloride is synthesized from chlorine and petrochemical feedstocks (usually ethylene) in a con tinuous closed process. The plants, which resemble oil refineries (and in some cases tire attached to them), are open to the air. Historically, the heavy exposures have occurred in the plants where vinyl chloride is polymer ized into PVC, the whitish powdery resin from which actual plastics tire made. It could make you "high" Polymerization is a batch process : vinyl chloride mon omer (Vf'M) and other substances are put into a pres surized vat. heat is applied, and hours later, when polymerization is completed, the vat is emptied, opened, and cleaned for the next batch. The process is full of leaks. In most of the early plants the gas could be smelled almost constantly (YCM has a faintly sweet odor that seems to be detectable at concentrations above 2,000 parts per million), and workers occasionally got "high" from the fumes. It is widely agreed that in this early period, lasting into the 1950's, exposures of several thousand ppm were common. During the 1950's, as the vinyl industry grew, a trickle of little-noted and often inconclusive medical reports be gan to raise doubts about the monomer's presumed harmlessness. In 1949 a Russian group found a hepatitislike condition in more than one-fourth of seventy-three P\T workers examined, and over the next ten years European researchers encountered other symptoms: skin lesions, a circulatory disorder, gastritis, and derma titis. to name a few. By the mid-19G0's these had been confirmed and were described collectively as "vinyl chloride disease." Later in the 1960's, acroosteolysis, a disease involving a degeneration of the finger bones, was identified among workers who clean polymerization vats. As these findings accumulated, producers began to reduce exposure levels. In 1961 the American Conference of Governmental Industrial Hygienists, a voluntary standards-setting organization, had put the maximum safe exposure at 500 ppm. During the 1900's industry began working to get much lower than that, and by the early 1970's exposure levels were generally in the 100-to200-ppm range, with short-term "excursions" to levels many times higher. In this general downward movement, Dow Chemical \AY0ZL BFG27036 5 was far and away the leader, [n 1961 it had conducted an animal experiment showing liver effects at levels as low as 100 ppm and had decided to get its own plants below 50 ppm. By the early 197n's.' Dow had achiever! average ex posures in the neighborhood of 25 ppm in its copolymer plants (one of which produces resins for Saran Wrap). In 197, Dr. Pierluigi Viola, an Italian physician stuely.,lir ;u-n>.'istenly'is ;'ni- Solvay. a major European PVC preduc1'!1, n-ported an uiiexpeetc- r-eivrry. After twelve months' exposure at do.pm ppm. many of his experi mental rats had developed cancers. Doubts about Viola's procedures led Montedison and other European producers to commission Dr. Cesare Maltoni to undertake a largescale animal experiment to see if this carcinogenic effect could be replicated at lower exposure levels. By the end of 1973 Maltoni's well-executed study had shown that levels of VCM as low as 250 ppm induced a variety of cancers in rats, including angiosarcomas of the liver. In June. 1974, he reported angiosarcomas at 50 ppm. American producers began to join the inquiry into vinyl chloride and cancer in 1973. Early that year the Manufac turing Chemists Association decided to commission two massive studies. One was an animal study somewhat like Maltoni's (it has since confirmed his findings!, The other was an epidemiological analysis of the morbidity and mortality history of American vinyl workers. In December, Dr. John L. Creech, a Louisville, Kentucky, surgeon who is plant physician for B.F. Goodrich's mas sive PVC installation there, received a report that one of the workers had died of angiosarcoma of the liver. Re membering that another worker had died of the same cause two .rears earlier, he notified a superior. In midJanuary, 1974, while a systematic mortality study of Goodrich workers was being organized, Creech received a report of a third angiosarcoma death. On January 22, B.F. Goodrich announced the three deaths and their cause. To date, a total of eight persons employed at the Louisville plant have been found to have contracted this disease. They blew the whistle themselves As of .January. 1974, literally all the information link ing vinyl chloride to cancer had been developed by the industry on its own initiative. As Ralph L. Harding Jr., president of the Society of the Plastics Industry, ob served. "This is a unique situation. Industry financed the studies, and industry blew the whistle on itself." But this was quickly forgotten in the furor that arose during the weeks following B.F. Goodrich's announcement. Within days, regulators, public-health doctors, and union officials had begun to dominate public discussion of the vinyl problem. Within weeks, the Louis ville Timex initiated a series of stories alleging that in dustry had engineered a Watergate-style cover-up of the angiosarcoma discovery, which it abandoned only when it saw that the information was about to leak anyway. This charge was symbolic of the manner in which the initiative passed out of the hands of industry. It was seized, rapidly, by a loose but not uncoordinated network of regulatory agencies, government research in stitutes. academic medical teams, labor unions, and other groups united by a common commitment to eradicate en vironmental causes of disease. This ``regulatory-medical complex" is largely the creation of a decade's federal legis lation in the medical and environmental fields. Its unoffi cial leader is Dr. Irving J. Selikoff, professor of community medicine at the Mount Sinai School of Medicine in New York City. The one-man power elite White haired, gracious, and preternaturally energetic, Selikoff is best known as the man who explored the haz ards of asbestos and who fought for many years to get them reduced. But a glance at his credentials shows him to hold so many other distinctions and positions that he constitutes a virtual power elite all by himself : a recipient of the Albert Lasker Award of the American Public Health Association, he is also director of Mount Sinai's Environmental Sciences Laboratory, governor and past president of the Xew York Academy of Sciences, editor in chief of Enr'n omu> ntal Rexccu-rh, president of the So ciety for Occupational and Environmental Health, and consultant to the A.F.L.-C.I.O. as well as to an almost end less list of medical organizations and government insti tutes. He seems personally as well as professionally close to nearly everyone who matters in government occupa tional medicine, and has excellent contacts in the press, which he uses skillfully. Though he insists that he is only a scientist, Selikoff is also a crusader and reformer, and the weapons he takes into battle, aside from his many personal talents, are research and publicity. Within a month of B.F. Goodrich's announcement, half of Selikoff's staff was working on a series of medical and epidemiological studies of workers at three older PVC plants. Researchers from the Harvard School of Public Health began an analysis of morbidity and mor tality in Goodrich's Louisville plant. The National Insti tute of Occupational Safety and Health, which does re search and standards development for OSHA. began a major epidemiological study of workers at four older plants, and together with OSHA sent out numerous teams to conduct "walk-through" inspections of PVC produc tion facilities across the nation. In May, Selikoff con vened in New York City a large international working group on vinyl chloride, held under the auspices of the New York Academy of Sciences. As Dr. Joseph K. Wag oner of XIOSH described the position of the many re searchers who entered the field, " `Seek and ye shall find' is where we're sitting right now." What they found was a great deal of information that linked vinyl chloride ever more closely to a variety of 3732005 6 BFG27037 diseases. Lind this information in turn generated news paper copy. To an attentive reader, the cumulative im pression conveyed was of a hidden crisis slowly uncov ered. With each passing week, the discovery of yet another angiosarcoma case or the release of a new report seemed to show the crisis to be graver and more wide spread than it had been the week before. The tacit message was that industry had failed, and that govern ment would have to step in and do something fast. Federal regulators were quick to respond. By early February XIOSH and OS HA were actively at work on the problem of workplace exposure. (See the report on page 4 .) By the beginning of April OSHA had issued an emergency temporary standard of 50 ppm and in May it proposed "no detectable level" as a permanent standard. But during the summer, the plastics industry, which had maintained a low profile during the preceding months, reassumed the initiative under the leadership of S.P.I.'s Ralph Harding and Jerome H. Heckman. The burden of the industry position was that OSHA's pro posal was not required on medical grounds and was tech nically and economically unfeasible. In its place S.P.I. advocated a phased reduction to 10 ppm as an average and 25 ppm as a ceiling by 1976. The industry case was set forth in considerable detail and with much documentation during the OSHA hearings that began on June 25. Making policy in a desert It was clear at the hearings that, in the end, the vinyl chloride decision was going to be made in an informa tional desert relieved by only the most occasional oasis of knowledge. It was established that vinyl chloride causes cancer and other diseases. It was also established that, over the course of two decades, industry had re duced exposure levels in its plants by a factor of some thing like 50 without experiencing notable hardship or burdensome expense. But beyond that almost everything was uncertain. One large area of uncertainty concerns the shape of the so-called ``dose response" curve for vinyl chloride between 0 and 50 ppm--the range within which, presum ably, OSHA will set the permanent standard. To date, no animal experiments have been completed at exposure levels below 50 ppm, and since historic exposure levels in most existing plants have been above that level, it is ex tremely Unlikely that epidemiological studies can reveal anything about human response below the level. The data for Dow Chemical's Midland, Michigan, copolymer plant, where exposures have been monitored for upwards of a decade, are difficult to interpret. Dow's own studies sug gest no adverse health or mortality effects for workers at exposures below 200 ppm; however, Dr. Selikoff's group reports a significant incidence of abnormal symptoms even among Dow workers. Where data are unsatisfactory, one must fall back on inference and theory--but these have proved even less satisfactory, and much more subject to dispute. At the theoretical level, there is disagreement over how cancer is caused. Advocates of the ``no detectable level" artrued for the so-called `one-hit" theory of cancer causation, which holds that there can be no such thing as a risk-free exposure to a carcinogen. The theory implies that m i/ identifiable exposure to vinyl chloride is certain to cause angiosarcoma, at however low a rate. But there is another theory of cancer causation, winch emphasizes the role of the body's immune system in com bating cancer. According to this theory, cancers appear when the immune system breaks down, [f what a carci nogen does is to weaken the immune system, and if the weakening process requires a certain level of dose, then it is possible that there is a risk-free level of exposure. At the present time, there is no definitive way to evalu ate the truth of these competing models. Thus when OSHA chooses a standard, it will do so in almost total ignorance of the different rates of cancer and other dis eases to be expected at different exposure levels. The cost of approaching zero The agency will be just as uncertain about the other major point in dispute--the level below which it is not economically feasible for industry to reduce exposure. "No detectable level" advocates point to the huge ex posure decreases that industry has already achieved, to the fact that many producers got below 50 ppm soon enough after the emergency standards were issued on April 5, and that not a few were far below that. To many regulators, it seemed obvious that industry could get to a near-zero level if it really wanted to. Industry representatives argued vehemently that a nondetectable level simply could not be attained. "Even a system that doesn't leak, leaks," thundered Todd C. Walker, president of Firestone Plastics, at the OSHA hearings. The companies also argued that efforts to ap proach zero would be extremely expensive. Firestone, for instance, detailed every capital expenditure that would be necessary if it tried to reach "nondetectable" exposure levels and concluded that the total cost would equal the entire value of its existing plant. Even then. Firestone insisted, it would not ultimately achieve a "nondetectable" exposure and would be forced to go out of the plastics business. By the end of the summer, it appeared that even the OSHA staff felt the standard might be unjustified. An August, 1974, report by the agency's Division of Program Evaluation and Research observed: "First, it is not clear that it is technically feasible to comply with the proposed standard without a shutdown of the entire vinyl chloride industry. Second, it is not clear from existing experimental and other historical data that a 'no detectable lex el' stand ard is justified. And third, it is quite clear that compliam t 3732006 BFG27038 7 with the proposed standard will require substantia! cap ital investments and lead times." They'd call it a sellout It' these lindities should lead OSIIA to i nmpromi.-e- - to set an exposure standard ut'. say. 25 ppm--the ayemp should not expect to be praised tor its moderation. It may even be assailed t'or violating its charter. The Occupa emal Sttfetv and Heal'h Ac' m [070 states 'hat OSHA. in ivL ila' 1 t".\ie nur t-rui.-, "shall set the stand.;! d which most ude'|UaA/ly a-.-tns, tc> die extent teasilue. on the basis of the best available evidence, that no employee will staTer material impairment of health or functional capacity even if such employee has regular exposure . . . for the period of his workin.tr life." Members of the regulatory-medical complex would surely insist that a compromise was incompatible with these words--and would see it as an unprincipled sellout sacrificing lives for dollars. Industry, meanwhile, is apt to view whatever level is allowed as an arbitrary interven tion. reflecting political emotionalism rather than reason. And whatever the level, it is hard to believe that the new vinyl chloride standard will do much to end the confusion and uncertainty that currently prevail in many different industries subject to regulatory power. The vinyl chloride hearings have made it clear that practically nobody in government, industry, or labor is willing to discuss these regulatory issues in trade-off terms. "We don't equate lives with dollars and cents--not at the Department of Labor," John Stender, Assistant Secretary of Labor in charge of OSHA, declares. Even spokesmen for industry seem unwilling to chal lenge Stender's formulation head-on. "If we know we're exposing our workers to a known health hazard, we get out of the business," says Dr. Ben Holder of Dow. In the course of the long argument about vinyl chloride stand ards, businessmen have shied away from asserting that some level of mortality might actually be "worth it." In stead, they have tried to smuggle some practical consid erations into the discussion by pointing to problems of "engineering and economic feasibility"--as if feasibility were an absolute. One reason for the general reluctance to think in costbenefit terms is to be found in the language of the Occu pational Safety and Health Act itself. But another rea son lies in the ethos of the regulatory-medical complex, which has something more on its mind than the rate at which people get sick or die. It is committed as well to a larger conception of the good society. In this society the idea of health is central. Ever more remote causes of disease would be eliminated. The role of medicine in this society would be different; it would no longer merely cure, but would actively redesign the environment and ways of living to prevent disease. In evitably, it would be a society in which doctors, by virtue of their expertise, possessed considerable power. The role of markets would be sharply curtailed, inasmuch as they often lead people to make decisions contrary to their bes medical interests. In this sense the regulatory-medical complex is a political movement. As such it perceives in issues such as the vinyl chloride standard a symbolic im portance that transcends the particular merits involved. They don't like business And, of course, it is an antibusiness movement in its underlying commitment. American regulatory agencies seem to reflect the times in which they were founded: the new regulation was established in an era of intense con flict and hostility to business, and there is little prospect of the movement's suddenly acquiring another personali ty. For all its unattractive implications for regulatory equity and consistency, this fact is not entirely without its redeeming aspects. By pressing industry hard, these agen cies will hasten economic modernization. It is clear that they have long since achieved immense success in raising health consciousness in industry and labor alike. As Dr. Ralph Langner, an industrial hygienist at Dow Chemical, says, "Vinyl chloride is to industrial hygiene what Rachel Carson was to the environmentalists." In any case, if Americans are now going to assume the responsibility of deciding what is a "socially acceptable risk," and thus of implicitly putting a price on human life, surely it is desirable that the critical decisions not be left entirely to business--or to any one group or center of authority. A process of indeterminate struggle between business and antibusiness forces, yielding decisions me political than rational, seems preferable to a system 1.. which a single cooperative establishment coolly announces the exact going rate at the close of every business day. Even so, it seems clear that the process of conscious ness-raising could usefully flow in the other direction as well. The regulatory-medical complex would not be any the worse if it had a clearer sense of the novelty of the concept of health it is promulgating and of the uneasiness of its relationship to the existing economic system. And it could take more fully to heart the potential conse quences of its regulatory interventions for ordinary liv ing standards. As G.J. Williams, vice president of Dow Chemical, remarked recently, "You could probably not find a single thing in the world that's essential, but they all go towards making life pleasurable. You can do with out almost anything, but not without everything." exd to Li w -xi BFG27039