Document XxELE87we4aVe2bnLVNXjBxd
FILE NAME: Asbestos Information Association (AIA)
DATE: 2016 Feb
DOC#: AIA051
DOCUMENT DESCRIPTION: Journal Article - The AIA and Its Role in Perpetuatinga National Epidemic
PUBLIC
Public H ealth Then and Now
AJPH
PUBLIC
"My an w ei to th e piohle-rn is if }ou hate enjoyed a good hid volule wot king w ith asbestos products u h \ not die irom it Theie's got to be some cause"
In the m iddle decades or the h 'th ce iu u t\ asbestos a m in eral w ith in su litin g md * tue tens-nn', p to p em es w as w idelv distnhuted rlnoughoLit the \m e n r.tti lm dsc ipe \ n u t e iu l used toi a \o i\ limited num bei ot put poses in the I'-'th centuiv bv the 1 'inns it w is used m thousands oi household uid mdList11il products in clud in g tdooi ules paints tooting im tetials catilhs plasties md even C luistin as n ee snow T h ete is a \e r \ t u b litetature on the lustoix ol the asbestos m dustiv V in o u s scholars have docum ented \\h tt the nidusU\ did to lu d e allo t illation and ih eieto ie del.n tenon that m ight lead to lestn ction s on its use I n s h o it these authois have illustiated tli.it as with the tob acco and lead m d ustiies the dangers ot asbestos and its specific. leh tion sh ip to cancel w ere cM ensivelv icpo i ted on in the m ediccl liter ctuic. but m in i mized and e \e n lu dden bv v a l l ows com panies and m diM duals
W * toeiis on the* e ah I T us sp e a fic tlh the \sbesios Iniotniaiion hssoiiaiioii North A jneiicu i \) \ \ k an m dusin ti ide group that had im eina tioiu l tic's ro and wot hc-J in tan lernw ith the Butish \sbestos'
11noi niation l oinm ntee and yshestosis Research (. o un oi md snnil.n groups in R anee the Benelux counmes and Vatidan av ja ' Est ibiishc'd m Decembei lT n the same month tint the O SH y et was signed into lew its go.d was to couuteuct the grow mg public attention to and gov ernment regulation ot asbestos as asei ions tlueat to workers and oonsuineis W* an.dv 7e how the mdusti \ sought to sl\ape public opinion and tegulatoiv polic\
The AIA claimed iliat .is a lesult ot is etioi is the O c cupaiiou.il Vten, and Health Administration (O S H \) legulatioixs adopted in m cotpo i ited most o f then suggestions especiaUv tint asbestos could continue to be used in a wide vatictv o f ecusuinei products without anv w arning il^our the d mget of cancer' Tilts was despite a nch histoneal kteutuie on asbestosis lung cancel and mesothelioma dating to e u h in the dull cetmiit '
The A1 \ was bom of lolins Mam tiles public relations c-lfoits In Octobet IT o the PuPlu RelitK'ns Subcommittee ot Johns M ui.ilic s Lnutonm eiit a! Health T.ck Force had a meeting with lepi esc`iu.iti\es tiom I lill A. Kiiowbou i public icLtUoiis
fit in to discuss the tot [nation of an orgaiiic.cion to addtess the giowing attention to the health effects ot asbestos pioduus the1, to.ued could lead to a ban Theietoie fiom its tonnation the ALA was a cieitute ot industrv and o f the Hill A Know lion public teiacions turn, now infa mous foi developingsti ctegies to countetact challenges to auu etv ot polluting induscues including tobacco le\d paint and asbestos Matthew SwetC'mc a graduate of the C oluinbia School of loui nallsm whose initial job w.is in the public tela lions department ot fohns Manvnlle in the Hiy's be came the hist executive societal\ ot the A H
He telated the \] \ s tiatisioi mation Irom an 'mlotimuon' oigaiuzauon to a defendet of asbestos
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Lxamimng pieviously underused corporate documents, we revisit the story of the Asbestos In formation Association/North America, an industry trade group that sought in the early 1970s to : ounferact the growing public attention to, and government regulation of, asbestos as a serious threat to workers and consumers. From the mid-1960s through the early 1970s, according to its own spokesperson, asbestos was exposed as "probably the most hazardous industrial material ever unleashed on an unsuspecting world " In retrospect, thousands of lives may have been saved i the Asbestos Information Association had publicly acknowledged this earlier. (Am J Public Health, Published online ahead of print February 18, 2016, e1 -e7 dor10 2105/AJPH 201 s.303023)
"My answer to the problem is: if you have enjoyed a good life while working with asbestos products why not die from it. There's got to be some cause."
-- E A . Martin, Bendix Coipomtion, to Noel Hendry. CanadianJohns-Manville Corp , 1966.1
a the middle decades of the 20th century, asbestos, a mineral with insulating and fire-resistant properties, was widely distributed throughout the American landscape. A material used for a very limited number of purposes in the 19th century, by the 1960s it was used in thousands of household and industrial products, includ ing floor tiles, paints, roofing materials, caulks, plastics, and even Christmas tree "snow."2 There is a very rich literature on the history of the asbestos industry.Various scholars have documented what the indus try did to hide information and therefore delay action that might lead to restrictions on its use. In short, these authors have illustrated that, as with the tobacco and lead industries, the dangers of asbestos and its specific relationship to cancer were extensively reported on in the medical literature but mini mixed and even hidden by vari ous companies and individuals. We focus on the early 1970s, specifically the Asbestos Information Association/North America (AIA/NA), an industry trade group that had interna tional ties to and worked in tan dem with the "British Asbestos
Information Committee and Asbestosis Research Council, and similar groups in France, the Benelux countries, and Scandanavia."4Established in December 1970, the same month that the OSH Act was signed into law, its goal was to counteract the grow ing public attention to and gov ernment regulation of asbestos as a serious threat to workers and consumers.We analyze how the industry sought to shape public opinion and regulatory policy.
The AIA claimed that as a result of its efforts, the Oc cupational Safety and Health Administration (OSHA) regula tions adopted in 1972 incorpo rated most of their suggestions, especially that asbestos could continue to be used in a wide variety of consumer products without any warnings about the danger of cancer.5This was despite a rich historical literature on asbestosis, lung cancer, and mesothelioma dating to early in the 20th century.6
The AIA was born ofJohnsManvilles public relations efforts. In October 1970, the Public Relations Subcommittee of Johns-Manville's Environmental Health Task Force liad a meeting with representatives from Hill & Knowlton, a public relations
firm, to discuss the formation of an organization to address the growing attention to the health effects of asbestos products they feared could lead to a ban. Therefore, from its formation the AIA was a creature of industry and of the Hill & Knowlton public relations firm, now infa mous for developing strategies to counteract challenges to a variety ofpolluting industries, including tobacco, lead paint, and asbestos.7 Matthew Swetonic, a graduate of the Columbia School ofJournal ism whose initialjob was in the public relations department of Johns-Manville in the 1960s, be came the first executive secretary of the AIA.8
He related the AIA s transfor mation from an "information" organization to a defender of asbestos:
In our original concept the Association would limit its activities to providing accurate, unbiased information on as bestos and health to the press, the public and to interested politicians and other govern ment officials . [But] for tunately--and properly--the Association has had the wis dom to alter its original limited concept of its proper functions, and now endeavors to assume whatever activities and respon-
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sibilities it deems necessary to protect the interests of the as bestos manufacturing industry m the United States vis-a-vis asbestos-health 9
Within months of its forma tion, the AIA had made the shift. One of the first tests of its true mission came in early May 1971, when the International Ladies Garment Workers Union held a news conference with Dr. Irving Selikoff, the nations foremost expert on asbestos-related diseases, to call attention to the fact that asbestos was used in certain imported womens coats, potentially creating dangerous consumer exposures. At the conference, Selikoffwas asked "what a consumer should do if she discovered she owned such a coat," to which he replied, `bury it.'"10Selikoffwent to the AIA with a specific request that, as an information service, the AIA should publically "condemn the use of asbestos" in the coats. However, Swetonic told the AIA's board of directors,
To condemn the use of the cloth on the basis of its being a health hazard would place the AIA/NA in the position of giving tacit approval to the contention that even slight exposure to asbestos can be hazardous, [which would] completely undercut our cur rent efforts to defeat local, state, and federal moves to ban asbestos-containing products.11
The AIA did not take a public stand, realizing that it could not both provide "accurate informa tion" and, as an instrument of this industry, defend its interests. It had to choose.And it did.
The activities of the AIA were generally defensive. By October 1971, the AIAs public relations campaign provided its vision of the health hazards of
asbestos. In a pamphlet titled "Asbestos and Health: Ques tions & Answers," the AIA asked, "Can a little bit ofasbestos kill you?" to which it responded, "Long term-medical studies of occupationally exposed workers show that low to moderate levels of exposure to asbestos do not lead to an increased rate of dis ease."12This was despite the vast literature that had accumulated since the early 20th century that indicated the opposite.As early as the 1930s, researchers documented that asbestos dust produced asbestosis even at con centrations invisible to the naked eye.With the recognition of the relationship ofasbestos to cancer it became clear that virtually any occupational exposure might cause disease and death.13 The AIA pamphlet also posed the question, "To what extent is asbestos an occupational health hazard?"The AIA acknowledged that asbestos-related diseases were not a recent-discovery; they dated back at least' to 1930.14But, it argued, those diseases did not reflect the kinds of conditions that workers faced in the 1970s and were a product ofpractices that had long been abandoned or improved,"when the dust con trol equipment in use was not as efficient or as sophisticated."15 This was a disingenuous interpretation of the historical knowledge of the dangers of asbestos. Since the 1930s clini cians had been discovering lung cancers in workers exposed to asbestos.10By the 1950s, major surveys and an epidemiologi cal study by Sir Richard Doll confirmed the observations of clinicians, pathologists, and radiologists worldwide who had documented lung cancer in asbestos workers.17Along with these observations went a critique of the relationship be tween the amount of exposure
and the safety of asbestos. Henry Smyth, who was research direc tor at the Mellon Institute and a long-time employee of Union Carbide, wrote that cancer made the older threshold limit values almost irrelevant-"At this time it is prudent to set the standard for a carcinogenic substance substantially at zero."18Irving Se likoffsuccinctly pulled together the emiirging consensus about the irrelevance of the threshold limit value as a measure of safety when speaking of asbestos and cancer in his classic 1964 article in theJournal of theAmerican Medical Association ^Asbestos Ex posure and Neoplasia.""Building trades insulation workers have relatively light, intermittent, exposure to asbestos," he noted. And yet these workers had very elevated rates of asbestosis, lung cancer, and mesothelioma.19 In 1971 OSHA issued an "emergency standard" for expo sure to asbestos dust of 12 fibers per cubic centimeter, which was dramatically lower than the level of exposure first established by the American Conference of Governmental Industrial Hy gienists in 1946 offive million particles' per cubic foot (roughly equivalent to 30 fibers per cc). In 1972 the National Institute for Occupational Safety and Health (NIOSH) proposed to significantly reduce the permis sible exposure limit to two fibers per cubic centimeter for protec tion against asbestosis, acknowl edging that there was "insuf ficient information to establish a standard to prevent. .. asbestos induced neoplasms by any all inclusive limit other than one of zero."20This proposed regulation was perceived as a dire threat to the asbestos industry and led the AIA to appeal to OSHA for re straint.The immediate problem, the industry argued, was that "past experience" proved that for
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"a sizable number of operations it will be impossible to reduce the levels to two fibers, no mat ter how much money is spent," and in light of the uncertainty of wliat constituted safety, it would be unfair to adopt an unwork able standard. "The simple truth is that no one, NIOSH included, knows for sure what a safe occu pational standard should be."21
NIOSH and OSHA sought to place greater and greater limits on asbestos exposures.The government argued that because of the lack of knowledge about what level of exposure could be safely tolerated, prudent public health practice demanded pre caution in the form of lowered exposures.The AIA took that argument and turned it on its head: because no populations have been consistently exposed at the levels NIOSH had sug gested and because there were no studies that "would suggest an excess of malignant tumors among persons exposed to no more than 2 asbestos fibers per cc of air...," there was no scien tific justification for setting levels so low.22As a political agency, OSHA adopted a pragmatic approach, setting the limit at five fibers per cubic centimeter in 1972 to be reduced to two fibers per cubic centimeter in 1976, giving the industry four years to reduce exposure to NIOSH s recommendation. OSHA stated that this would reduce the num ber of cancers while not neces sarily eliminating all of them.23 The AIA also objected to the recommendation by the OSHA Advisory Committee that the warning label include the word "cancer" because
such a label would spell the de mise of numerous major prod uct lines ot the industry, includ ing vinyl asbestos floor tile, asbestos pipe, and any other
product that is sold directly to the consumer market. . .
This objection was derived from the industry's contention that such a warning was not necessary because "the majority of asbestos-containing products ... [were] locked in," that is, bonded with various resins and other stable materials.25A few months later, Swetomc privately acknowledged the limits of his publically stated position. Using the example of cement pipe with asbestos embedded in it, he described the very problem that had been identified historically. "The field cutting or trimming of asbestos-cement pipe, might produce levels in excess of the standard, but only for the man doing the actual cutting and only intermittently or rarely." But he opposed placing a warning
on such asbestos-containing products because it would "alarm all those handling the product, when only one man has a poten tial excess exposure."26
In June 1973, less than a year after Swetomc had written to member companies about label ing asbestos products, he gave an address to the Asbestos Textile Institute, an older, more nar rowly focused asbestos trade as sociation. In this private address, Swetomc said,"The medical literature is full of solid evidence linking asbestos to disease," cit ing "more than 2,000 medical articles dealing with the health risks ofasbestos."27These were primarily aimed at the medical and professional communities, but he observed,"Starting with Paul Brodeur's infamous New Yorker article of March, 1968, asbestos has since grown into an
The JM Jeffrey Asbestos Mine, Asbestos, Quebec.
Note The Town is positioned around the nm o f the pit, which measures about 1 mite m length and 1200 feet deep Most o f the asbestos sold from this mine was being exported to third world countries. In 1988 the mine operated 364 days, on a double shift. This was the largest chrysotile asbestos mine in the western world.
Source Photo by Bill Ravanesi, producer o f the documentary exhibition, "Breath Taken. The Landscape & Biography o f Asbestos " Printed w ith permission
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item of major press interest."-3As a result, public relations was now "the single largest consumer of time, effort and money.within the Association."
This publicity was over whelmingly negative, and the AIA had done all it could "to present the press with a balanced view of the asbestos-health situ ation."29He told the audience that the AIA had prepared and printed an Asbestos and Health Information File,"which we have mailed to some 3,000 news papers, magazines, trade pub lications, radio and TV stations, science writers, etc. across the United States."30In addition, the AIA had disseminated "timely, constructive news releases and articles" and prepared "carefully selected responses to editors as a result of`damaging, irrespon sible stories.'"31But now a new approach was needed. According to Swetornc, "The pres relations battle will ... be won, not when the media starts to print positive or balanced articles about asbes tos, but when the press ceases to print anything about asbestos at all."32 Ironically, the Asbestos information Association saw as its new goal the exact opposite. From Swetonic's viewpoint not all was lost, despite the spate of negative publicity about asbestos.As he told the ATI, "Having [heard] the bad side of the public relations problem, it's time for some good news.""The good news is tliat despite all the negative articles on asbestoshealth that have appeared in the press over the past half dozen years, very few people have been paying attention."The AIA hired a prestigious public relations firm that interviewed "more than 2,000 demographically selected Americans," reporting that "only 22% of the American public are aware of the health hazards of asbestos." O f these,
80% considered it "a hazard only to those who are occupation ally exposed," a result that he thought "should be reassuring."33
Swetornc understood the irony of what he was saying. Here was an information service that was celebrating that the public was not understanding the information that was being publically reported. As Swetornc told the AIA board of direc tors six months later, the results of their survey "show that the average man has little concern with or awareness of the health problems being associated with asbestos."34
Although the industry took solace in the public's lack of understanding, they worried that federal regulators might act anyway.The AIA feared that even though OSHA's permissible exposure limit was about to be reduced to two fibers per cubic centimeter in 1976, there would be continuing pressure to reduce it further, a fear confirmed when NIOH proposed such a reduction to 0.5 fibers per cubic centimeter in 1975 and then 0.1 fibers per cubic centimeter in 1976, then considered the lowest detectable level.35
Guy G. Gabrielson Jr, the vice-president of the AIA, reported to his membership the position OSHA officials had taken at an AIA-sponsored Industry-Government Confer ence m September 1976. OSHA "seems to say that there is no threshold," he told his members. "You get to zero risk at zero exposure, and in the case ofall diseases that will occur during a working lifetime." He reported that the OSHA official "seemed to say ... that the only way we can be sure that there is no risk ofdisease is to ban asbestos." This was a position that was the same as NIOSH's recom mendation ini 972, when they
argued, "To prevent such diseases including asbestos-induced neo plasms only a level of exposure approaching zero could truly be protective.36In 1976, NIOSH went further, confirming the association's fears, asserting that when considering cancers, "only a ban can assure protection against effects of asbestos."-'
Gabrielson made dear that this was untenable for the asbestos industry: "We can't go to zero risk." Rather, the industry had to reject OSHA's and NIOSH s position by argu ing that the "two fiber level is sufficient to protect our work force during a working life time," although he "admit[ed]" that they could not "prove that, particularly m the case of meso thelioma."38
At every stage of the standard-setting process, the AIA fought a rearguard action to limit the burden any regulation might place on them, especially an effective ban on asbestos ex posure. Swetornc claimed credit for getting OSHA in 1972 to accept most ofAlA's recommen dations, arguing that its success was "a gauge of the effectiveness of the total industry involvement in this most crucial matter."39 He pointed out that there were 11 majcfr parts to the OSHA standard, and of these,"the industry position was accepted totally by OSHA on nine of the eleven, about 50 per cent on a tenth, and totally rejected on only one." In 1976, Gabrielson outlined a program to forestall government action to reduce the permissible exposure limit:
I have recommended co the Executive Committee of the AIA/NA thaL we use every tool in our command co make our point with the regulatory authorities, that we exhaust our administrative remedies, and if at that point we still
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do not have che kind of stan dard we think we require to run our businesses that we go ahead and go to court to challenge an unsatisfactory regulation. I believe the system permits us to do this and we ('an do that with a clear con science 40
The industry believed it was under assault not only from government regulators but also from the courts, where diseased workers were beginning to bring liability suits. In 1971 the Borel v.
FiberboardArticle Products Corpora
tion decision provided the basis for thousands of liability lawsuits against asbestos manufacturers, such asJohns-Manville, Raybestos, .ind companies that made products out of asbestos. By 1976, the effects of these lawsuits were having a dramatic impact on the industry.T he AIA noted "problems confronting the industry m regard to cancellation of product liability insurance coverage, increases in product liability insurance premiums and higher deductible features."
At its board of directors' meeting in December 1976, Vice-President Gabrielson feared
that some customers of As sociation members view the product liability problem as. an indication that an impar tial judge, i.e , the insurance companies, has come to the conclusion that asbestos is a more hazardous material than industry has told them 41
It it was to survive, the industry had to develop a co ordinated legal, public relations, and medical program to counter the growing threat.They hired Phillip Enterline, then chair of the Biostatistics Department at the University of Pittsburgh, to write a state of the art review of the literature on asbestos and disease to prepare for coming
lawsuits.They also began to interview "physicians around the country who might qualify as expert witnesses in 3rd party litigation."42They also began to hire researchers to "prove" that the main threat came from crocidolite,"blue asbestos," and amosite, not chrysotile, the mainstay of the American asbes tos industry.43
In the succeeding decades the asbestos industry devoted huge resources to recruiting scientific experts, lawyers, and medical personnel to fight the lawsuits brought by thousands of victims of their "magic mineral." In ad dition, from the 1980s through at least the first decade of the 21st century the AIA contin ued its rearguard action to fight warning labels on asbestos prod ucts, oppose a ban on the uses of asbestos, and in general defend the interests of the industry.44 Workers and family members dying from asbestosis, lung cancer, and mesothelioma would drive major corporations like Johns-Manville into bankruptcy. At the same time that victims were holding compa nies accountable, OSHA was promulgating new, lower and lower standards (the permissible exposure limit was reduced to 0.2 fibers per cubic centi meter in 1986 and, m 1994, two decades after NIOSH first proposed it, a 0.1 fibers per cubic centimeter permissible exposure limit).National and international organizations such as the International Agency for Research on Cancer, the Inter national Labour Organization, the World Health Organization, and NIOSH concluded that all forms of asbestos were human carcinogens. Despite the most fervent efforts of the industry to protect itselffrom lawsuits, the asbestos industry became nearly as notorious as the tobacco
industry in the public mind. Matthew Swetonic, the first
executive director of the AIA, who later worked for the tobacco industry as he had for asbestos manufacturers, declared the "death of the asbestos industry" in the 1990s."What happened?" he rhetorically asked."What drove that once mighty industry into the dust? Its simple," he said. "During a relatively short period of time from the mid1960s through the early 1970s, the `magic mineral'was exposed for what it really was--probably the most hazardous industrial material ever unleashed on an unsuspecting world." Swetonic spoke with sardonic author ity:"! know. I was there."45 In retrospect, thousands of lives may have been.saved if he, and the Asbestos Information Associa tion, had said this earlier. >4jPU
ABOUT THE AUTHORS
Gerald Markowitz is with the Department of Inteidisciphmry Studies,JohnJay College, New York, NY; the PhD Programs in History and Public Health, Graduate Center, City University ofNewYork, NewYork;and the Department ofSodomedical Sciences, Mailman School ofPublic Health, Columbia University, NewYork, N Y David Rosner IS with the Department ofSociomedical Sciences, Mailman School ofPublic Health, Depart ment ofHistory, and Centerfor the His tory and Ethics ofPublic Health, Columbia University
Correspondence should be sent to Gerald Markowitz, PhD,JohnJay College, 524 West 59th Street, Room 6 65 06, NewYork, N Y 10019 (e-mail gmarkowitz@jjay.cuny edu). Reprints can be orderedat http-/ /mine.ajph oig by clicking the "Reprints"link
This article was accepted November 21, 2015
doi. 10.2105'/AJPH 2015.303023
CONTRIBUTORS
The authors contributed equally to the research, writing, and conceptualization of this article. AThCeKaNutOhoWrsLwEoDulGd MlikEeNtoTaScknowl edge that many of the primary source documents were gathered in the process oflitigation regarding asbestos-related diseases.These documents are available online at http.//wwwtoxicdocs org, a Web site ofcorporate memos, letters, reports, and other papers developed
through the cooperative efforts oi the Center for the History and Ethics ol Public Health, Columbia University, City University of NewYork; and the Center for Public Integrity The authors have appeared as expert witnesses on behalf of plaintiffs in asbestos lawsuits
ENDNOTES
1 E.A Martin, Bendix to Noel Hendry, Canadian Johns-Manville Corporation, September 12, 1966 2 See E R.. A Merew^ther and C W Price, Report on Effects ofAsbestos Dust on the Lungs and Dust Suppression in the Asbestos Industry (London, UK Her Majesty's Stationary Office, 1930) foi a discussion of the growing uses of asbestos' in the 1930s. 3 See, e.g., Bairy I Castleman and Stephen L Berger, Asbestos Medical and Legal Aspects, 5th ed (Englewood Cliils, NJ Prentice Hall Law and Business, 1993), Paul Brodeur, Outrageous Miscon duct. The Asbestos Industry on Tnal (New York, NY Pantheon Books, 1985), Jock McCulloch, Asbestos Its Human Costs (St Lucia, Australia University of Queensland Ptess, 1986), Jock Mc Culloch, Asbestos Blues- Labour, Capital, Physicians and the State in South Africa (Bloomington, IN- Indiana University Press, 2002), Geoffrey Tweedale, Magic Mineral to Killer Dust Turner & Neuvll and the Asbestos Hazard (Oxford, UK. Oxford University Press, 2000), David Egilman, "Dust Diseases and the Legacy of Corporate Manipulation of Science and Law, InternationalJournal of Oc cupational and Environmental Health 20, no 2 (2014): 115-125 Jock McCulloch and Geoffrey Tweedale's, Defending the Indefensible The Global Asbestos Industry and Its Fightfor Survival (Oxford, UK Oxford University Press, 2008) provides an important perspective on the asbestos story, including the point that the As bestos Information Association was part of an international effort to defend "the indefensible " 4 Asbestos Information Association, The Asbestos Information Association/North America (Washington, DC, ca 1972), 3 5 Asbestos Information Association, Chart comparing OSHA, National Insti tute for Occupational Safety and Health, and industry-suggested regulations, at tached to Swetonic to AIA/NA Member Companies, June 12, 1972 This study is based upon an examination of previously underused corporate documents now available through the discovery process of lawsuits against the asbestos industry These documents are pubhcally available on the Web site http //w w w toxicdocs org, sponsored by the Columbia Univer sity Center for the History and Ethics of Public Health, Graduate Center of the City University of New York, and the Center for Public Integnty.
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