Document baq9xBNQkVvzV5e7a1LKjex1k

Asbestos Information Association/North America 22 East 40th Street New York, N. Y. 10016 212-689-3378 PLAINTIFF'S EXHIBIT UC-3981 January 30, 1973 Gentlemen: As mentioned in my memo of January 17, attached are two documents concerning the Bill introduced by Congressman Dominick Daniels to repeal the Federal Metal and Nonmetallic Mine Safety Act and to transfer standard setting and enforcement responsibilities for U.S. mining operations, including asbestos, to OSHA. The two documents are (1) an excerpt from the Congressional Record of January 11, and (2) an analysis of the situation by our government affairs consultants. I In recent weeks, we have received a sizable number of news paper clippings concerning a recent paper by Dr. Mearl Stanton of the National Cancer Institute on fiber size being the main determinant in the causation of mesothelioma in test animals. Both the DPI and Lcs Angeles Times articles on the study (a copy of the latter is attached) contained the statement that "asbestos is second only to cigarette smoking as a cause of lung cancer." V7e are trying to track down the source of this comment (it is unlikely that it came from Dr. Stanton himself). The L.A. Times attributed it to the Institute, the UPI story did not. On the other head, a story (also attached) from the Occupational Health and Safety Letter did not use the quote at all. In any case, attached is a copy of Dr. Stanton's paper as presented at the Lyon Conference last October. Far. from being a damaging study, Dr. Stanton's research indicates that electron size asbestos fibrils are of little or no concern in the causation of cancer. Since it is fibrils of this size that are being found in community air, in drinking water, beverages, drugs, wine, beer, etc., his findings could prove a valuable weapon in defending attacks in these areas. Also enclosed is .a copy of an article from the December issue of Occupational Hazards magazine, consisting of an interview of Dr. Selikoff on various occupational health topics, including asbestos. Mike Isser of Cunningham & Walsh contacted the magazine on behalf of the Assocatiort, -and they agreed to do an article on the efforts being made by the asbestos industry UCC011759 A 1 954 o 2 to comply with the OSHA standards. Arrangements will be made within the next few weeks for a writer from the magazine to interview both me and an environmental control expert from the industry. We will keep you informed on the progress with this article. The final item enclosed is a clip from the Occupational Health and Safety Letter concerning an automatic asbestos fiber bag opening device recently developed by Johns-Manville. The announcement was made in a speech by E. M. Fenner at a safety conference in Olympia, Washington, late last year, and was publicized in a press release put out on behalf of the Association by Cunningham and Walsh. Sincerely, Matthew M. Swetonic Executive Secretary Enclosures I UCC 011760 CONGRESSIONAL RECORD --HOUSE January 11, 1973 Statement by Rap. Dominick V. Daniels (D-'.i.J.) intro ducing HR 1720, a bill to repeal the Federal Metal and Wonmetallic Mine Safety Act. SAFETY1 ANT) IITALIK IN METAL AND NON'i; iMLwIC (Mr. cor:;-::cr: v. panthls a sum and was j;ic;i ta extend liis remarks ut i>i:;c-.::i in me IIccor.o a:nt to Include cxuuuic-ous m.v.icc.) Mr. DOMINICK V. DANIELS. Mr. incRt of Labor. TTmt is what my bill does, Sprker, I am today introd'iciq'T and it ipv'ircs that the Department of tion to repeal tlie Fctitral Meial and Labor wiil have sufficient cxpcner.ce m Nonmctxlilc Mir.o Safety Act because, tlie mining field by transferring to that paraaoxie.il as it may sound, that la the Department the personnel m tiic Interior best way to promote health and safety Department who have been engaged in in these mines. Tiie eJcct ol the reveal is the administration of the law. not to leave metal ar.d ronmetallic min We have, as I raid before, learned ers without the protection of Federal much about tlie relative efficacy of dif safety law; rather it is to make them ferent enforcement procedures in occu subject to the Occupational Sa/cty and pational safety and health laws. The Gc- Health Act of 1070, a much stronger and cupationai Safety and Henltn Act of 1970 more elective statute chan the Mecal is Uie distillation ot that experience. It and NonrnecalUo Mine Safccy Act. improves in many ways the procedures of The Metal nncl Nonmetauic Mine the Metal and NmunctaUic Mine Safety Safety Act rax a (orvarii-looking. pro Act. and I am attaching to my state gressive piece of iegisiation when it was ment a memorandum outlining the enacted, and I am proud to have been weaknesses of that act which are un a member of the subcommittee that de proved in the Occupational Safety and veloped it. But no have now had 6 rears Health Act. ' of experience under that act, and wc Mr. Speaker, death and injuries in tha have also--through the enactment of the mines are not inevitable. Effective safety Federal Coal Mine Health ar.d Safety and health laws effectively acministered Act of lf;D ar.d the Occupational Safety can make a difference. It is time that the and Health Act of 1970--acquired a great ir.ctal and nonmetallic miners of this deal more experience in tvntins safety country received the protection that they and health legislation. deserve--and that my bill will provide. The Select Labor Subcommittee's I include the following: hearing last year demonstrated at least WEAKirrssES or Ptraatc Law 8C-577--Feasant. two major trci.hneeres in the Metal and ilrrii ahd xoMamtuc ilinc S*rxrr Nomnot.iliic Mine safety Act--and my Act btU Is designed to correct both of them. TOHSAltSS The first weakness is in the administer There are no mandatory interim standards. ing agency. We placed enforcement of safety ar.d health responsibility in the Bureau of Mines because we thought that its tech nical expertise in mining operations made it the iogicai asency to protect tiis There is no ttrne_ltTr.lt within which per manent mandatory* standard.! must be set. The Secretary of Interior is bound PI for mal rule-making procedures which can eftea be lengthy. Under a state plan, standards do not have to be at lease as cuectlve as the federal ones. worker's safety and health. But we were There Is no provision for a variation In wrong. The Bureau of Mines' basic char standards and for the employees to be in ter is to promote production and that, we have found, is inconsistent with rigorous enforcement of safety laws. .Safety ar.d maximizing production are not s-ways consistent goals--ar.d the Bureau of Mines has shown, that workers will not be adequately protected while their lives are In the hands of an agency that is "pro duction first" oriented. formed of one. There are no emergency temporary stand ards. There to no general duty to cover unique circumstances where no standards have been promulgated. There to no distinction In the standard* between gassy and nongassy males. IHPOSCTMIXT Inspections The failure of the Eureau's enforce ment program is evident from the fig ures. The injury frequency rates have not declined in the mcvnr.cs subject to this act. while experience under the Longshore Safety Act. administered by The Inspector to required to visit each mine only once per year. There to no prohibition against advance notice of an inspect ton. There to no provision for the employee rep resentative to accompany the inspector. the Department of Labor,, demonstrates conclusively that a well enforced surety law will bring Injury ratc-s down. There to no provision fer the employees to get the results of an inspection. There to no reo.uirement for ari Inspector The most appalling evidence of the in- to re'.nspect to determme if an employer has effectivcnc.-s of the Bureau of ALr.CS pro corrected a violation of a standard. gram in the metal mining area is the Penalties disaster at the Sunshine Stiver Mine in There are no mandatary penalties. Kellogg. Idaho, in May 1079. The interim There ore only permissive ctvtl penalties: report of the independent hearing exam (1) it the Secr-tary of Interior chooses to iner on that disaster is a tragic indict bring a civil action for failure to correct a ment. Let mo just quote a few sentences violation of a standard; from his report: (2) II the Secretary of Interior t-kuom io It is evident that a larce number of deaths ar.d me magnitude of me disaster are a direct result of inadequate s.viecy stand ards. tndanrv-tvltie peer -ufotv practices, the bring a civil action iu the DEirict Court for failure to abide by a reporting requirement: (3) If the Secretary of Interior chooses to bring a civil action for an employer s refusal leek o? training of the miners m the even: ot a disaster, ar.d cite fact that no one c\;>'.vicct is Ptr-wer w mis r*r"itt:.ir to o-c*ir. T'-.frt;:rr. :*.v only are mr.ie standards tn.ide- q.:...*e. but thrv have berl tainted and rvu- ucrcu it:, le.-t.vc by iulsr,.: t -- ..oil. to permit an lu-pectiou or for interference with an inspector. There arc pcrui-M-ive criminal penalties if: (It the Secretary of Interior nishr-. to bring an .-.clion for reru-ai to comply with a Withdrawal o'.1. r i;i c:atta cf li.'tiniia. nc dan We tvili not l:?.vr a vi-prolix cnforcc- ger ciivin;; death or serious plirsical l:..rm; mtut j'fo.rvqtn m ihn iiuui-iry iinttl 7.0 12) or refusal to comply with an order of tram, for rcsjxnwibihcy to uic Dcp.in- debarment. A 1 954b UCC 011761 MINE SAFETY ANT) HEALTH Policy Developments Metal and Non-Metallic Mine Safety: Congressman Dominick Daniels (D-N.J.), chairman or the house Select buocommittee on LaboT, has introduced legisla tion which would strip the Department of the Interior of its responsibility for the Metal and Non-Metallic .'Line Safety Act of 1966. Daniels' bill would transfer this responsibility to the Department of Labor's Occupational Safety and Health Administration. Such action has long been favored by organized labor, particularly the United Steelworkers, who have most of the metal and non-metal mines under contract. The Steelworkers demanded the transfer of responsibility last year following the Sunshine Silver Mine disaster which killed 91 miners. During the oversight hearings held on the disaster by Daniels' subcommittee. Steelworkers legislative director, John Sheehan, said that the Department of Interior's Bureau of Mines was too cozy with the private mining interests to adequately enforce the law. In commenting on the disaster. Steelworkers President I.W. Abel demanded that "Congress act to shift responsibility for enforcement of metal and non-metal mine safety to the Occupational Safety I and Health Administration. . . " The mechanism of the Daniels' bill which would effect the transfer is the repeal of the Metal and Non-Metallic Mine Safety Act, thereby placing the mines under the jurisdiction of the Occupational Safety and Health Act. The bill ensures that the Department of Labor will have the necessary expertise in the mining field by transfering to OSHA the Bureau of Mine's personnel who have been engaged in the administration of the mine safety act. On the day he introduced his bill (HR 1720) Daniels stated that 'The Bureau of Mines basic charter is to promote production and that, we have found, is inconsistent with the rigorous enforcement of safety laws. . . the Bureau of Mines has shown that workers will not be adequately protected while their lives are in the hands of an agency that is 'production first1 oriented." The bill has a high priority with Daniels, and his subcommittee can be ex pected to hold hearings sometime during the spring, if not sooner. According to a subcommittee spokesman, the bill will probably be the second order of business following the committee's work on public service jobs and manpower policy. Since the subcommittee has not yet organized itself, this time schedule may change over the next few weeks. Forecast/Assessment GRC expects a similar bill to be introduced -shortly in the Senate and it will probably be initiated by Sen. Harrison Williams (D-N.J.), chairman of the Senate Labor and Public Welfare Committee. Tnere is a good possibility that this legislation will pass during the 93rd Congress. UCC 011762 A 1 9543 j j t Scientist says chemical make-up not to blame UCC 011763 A 954 -j? Occupational Health & Safety Letter, January 8,1973 NEW STUDY DEMONSTRATES MECHANISM OF ASBESTOS EFFECTS: The carcinogenic activity of asbestos is due entirely to its fibrous structure, regardless of the chemi cal composition of the fibers, according to a scientist of the National Cancer Institute. Dr. Mearl F. Stanton of NCI's Laboratory of Pathology reported on his asbestos study in laboratory rats at a conference in Lyon, France, on the biological effects of asbestos. The series of experiments was undertaken to test the ability of various fibrous and non-fibrous sub stances to cause cancer of the pleura. Results showed that very fine fibers of asbestos, glass or sapphire caused a high incidence of pleural cancers in the rats, while coarse fibers or powdered material of the same compositions only rarely caused cancer. The carcinogenic fibers were between one-half and five microns in diameter and less than 80 microns long (less than one-hundredth as thick as an eyelash and under one-tenth as long, says NCI). He and his colleagues used surgical methods to implant asbestos-covered glass-mesh pads directly against the pleura of rats. The pads remained in place until the rats were autopsied: then the pleurai mem branes were examined for cancer at the site of asbestos exposure. f High rates of mesothelioma, ranging front 58 to 75 percent, were found in 450 rats treated with asbestos fibers, regardless of which of three chemically distinct types of asbestos (crocidolite. chrysotile or amosite) were used. The rate of cancer production by various asbestos samples did not depend on the presence or absence of impurities, and neither of two common metal contaminants of asbestos tested separately produced any cancers. Treatment with fine particles of silica, the major constituent of all types of asbestos, caused only one mesothelioma among 48 rats. Thus, Dr. Stanton said, neither the chemical composition of asbestos nor the presence of impurities could account for its carcinogenic potential. In one experiment, a sample of asbestos was ground to reduce its fibers to submicroseopic size and very short lengths. This treatment reduced cancer incidence in test rats to less than half the rate in rats exposed to natural fibers of asbestos. The g/ass-mesh pads alone did not cause cancer, but mesotheliomas occurred in rats exposed to glass that had been treated to reduce it to small fibers, making it comparable to asbestos in size. At the Lyon conference. Dr. Stanton described more recent studies designed to test whether particle size and shape are the critical factors in causing this type of cancer. In these experiments, rats were ex posed by the same technique as before to particles of asbestos, glass or aluminum oxide of many different sizes and shapes. After two years, fibers of all three materials have been found capable of causing high rates of pleurai cancer in rats. Two standard samples of asbestos, two of very fine fibrous glass, and a sample of fine sapphire (aluminum oxide) "whiskers" caused cancer in more than half of the 150 rats that have been autopsied so far. Lower rates of cancer, between 5 and 40 percent, occurred in rats treated with either long, thick fibers or short, thin fibers of glass or asbestos. None of the 150 rats exposed to two samples of fully pulverized asbestos, non-fibrous aluminum oxide, or two samples of glass with large fibers have so far developed any cancer. "We know that asbestos libers cause cancer in man," said Dr. Stanton. "We have no evidence on whether other kinds of fibers will uiso prove hazardous. It's rare to find other substances with fibers the same size as asbestos, and few people are known to have been exposed to them. But the resuits in ani mals suggest that it would be judicious to avoid inhalation or ingestion of any finely particulate fibrous material." ' UCC 011764 i 9548 BIOLOGICAL EFFECTS OF ASBESTOS LYON, October 2-5, 1972 Paper 43A Some Aetiologic Considerations of Fiber Carcinogenesis Mearl F. Stanton I (With the technical assistance of Constance Wrench & Eliza Miller) UCC 011765 A i 054 3 43A - l SOME AETIOLOGIC CONSIDERATIONS OF FIBER CARCINOGENESIS by Mearl F. Stanton (vlth the technical assistance of Constance Wrench and Eliza Miller) The Laboratory of Pathology, National Cancer Institute, Bethesda, Maryland, U.S.A. SUMMARY Various structural forms of asbestos, fibrous glass, and aluminum oxide have been tested for carcinogenicity on the pleura of rats. Preliminary results indicate that all three materials when composed predominantly of durable fibers between 0.5 and 5 microns in diameter and lengths of less than 80 microns are more carcinogenic than fibers smaller or larger than these dimensions or non-fibrous materials of similar composition. The carcinogenicity of asbestos, glass, and aluminum oxide is primarily related to its structure rather than to physicochemical properties. A :C55C i UCC 011766' 43A-2 The exogenous agents vhlch contribute to the cause of cancer generally fall into 1 of 3 major groups{ ionizing radiation, chemicals, and viruses. There is a wealth of speculation as to how the members of these groups act to induce cancer, but the mechanisms of their action remain unknown. Asbestos is of particular Interest as a carcinogen because it has attributes of two of these groups. In all its forms, asbestos contains chemicals that are carcinogenic under certain conditions. At first hand, the various metallic ions or the polycyclic hydrocarbons that are either inherent^ or acquired through processing would seem the best explanation for i asbestos carcinogenicity. On the other hand, asbestos particles that are within the dimensional range of viruses are abundant in all forms and conceivably these submicroscopic particles could act In a fashion similar to viruses, whatever that may be. However, there is reasonably good evidence that neither of these attributes are related to the carcinogenicity of asbestos. The evidence for this conclusion can be summarized as follows: 1. There is no indication that any of the asbestoses are contaminated sufficiently with known carcino genic hydrocarbons to account for their carcino genicity, and rigorous extraction of those hydrocarbons present in asbestos does not affect its carcinogenicity for the pleura of the rat (Wagner, J.C. et al. 1970). 2. Variations in Inherent metallic content of various types of asbestos are great, yet these various types of asbestos show only slight differences in carcino genicity (Harrington, J.S., 1965*, Timbrell V, 1970; Wagner J.C. ct al. 197CB; Stanton e al. . 1972). UCC 011767 A ' 9 5 5 t 43A-3 3> Finely particulate metallic nickel, stainless steel, or non-crystalline silicon dioxide applied to the pleura of the rat are not sufficiently carcinogenic to account for the carcinogenicity of asbestos through mill contamination (Stanton et al. 1972). A. Reduction of fiber size by partial pulverization of asbestos, a process which increases contami nation by metallic particles and increases the number of submicroscopic fibrils in asbestos, reduces its carcinogenicity (Stanton et al. 1972). 5. Hand-cobbed crocidolite ore^ hand milled without metallic contamination^ is equal in carcinogenicity to machine-milled crocidolite (Stanton et al.1972). 6. Non-asbestiform fibers such as fibrous glass are Increasingly carcinogenic as they approach the size range of milled asbestos fibers (Stanton et al.1972). r One thereforenust consider that the structural features of asbestos may be the critical factor in its carcinogenicity and it is toward this hypothesis that we have directed our attention. If the structural features of asbestos are important, then it follows that similar fibers, if sufficiently durably should also induce tumors and on this reasoning we have based a large series of experiments. These experiments are still in progress; only preliminary results of part of them are available at this time* For this reason interpretations are limited. _ A ;9oo UCC 011768 43A-4 The interpretations of tumor incidence are reasonably conservative and may need to be revised upwards in the final calculations. The analysis of fiber distribution by size is admittedly crude and subject to considerable error, but again ve have tried to be conservative in our interpretation. Materials and Methods: Various specimens of crocidolite, chrysotile, fibrous glass, and fibrous aluminum oxide were applied by open thoracotomy to the left pleural surface of 30, 11- to 14- week-old, female Osborne- Mendel rats at a single standard 40 mg dose level by a method previously described (Stanton et al., 1969). The single unique aspect of these experiments is that all test materials were applied to small 45 mg fibrous glass pledgets prior to application. The * glass pledgets are composed of large-dianetered fibrous glass which when intact has no apparent carcinogenicity in itself. We use it simply as a convenient and accurate means of uniformly applying the test material to a wide surface area of the pleura. The test materials are listed in tables 1-4. The UICC standard reference sample? of crocidolite and chrysotile A have been previously described (Timbrell V. 1970). These samples were treated by grinding in a stainless-steel ball mill (Spex model 5000) to produce the three pulverized samples, and the crude fibers were stripped by hand from hand-cobbed ore specimens, with an attempt to retain bundles of fibers as long as feasible without contamination by extraneous mineral. This processing was previously described (Stanton et al.1972). The fibrous glasses were obtained from both the Owens-Coming Fiberglas Corporation, Toledo, Ohio, and the Johns-Manville Research and Engineering Center, Kanuille, New Jersey. A " 9 5S 3 UCC 011769 f] \ n r / t ! > \t l r J fI 1 tol ahr to to 4 K 4O eU*-v (toI *c-* *t4o H Q tot^oo 0 o >4 9 0* <*P> t; *4 5 #"* uto *hto* 6to1 to i 5 # <** O>D** fot R*. t<r>*>t H> D C At -- ft -. W e t-r KtBPr 1O-1 OH. 1- D, e*Bt* Atso> ifl W* *I1 VX 3 U lj ir>. 1 I | 1 it? i It i-i U n MOO i*e I X ru oX i cu o io fU AA k VO 6 *3Y-lo UCC 011770 < A3 A-It TABLE 1 KESOTHFLICMA INCIDENCE IN RELATION TO DISTRIBUTION OF FIBERS BY SIZE HIGH 1KCIDZNCE CROUPS ( >501 MESOTiELICMAS) Length -*[>.5 > ,,H Dienetex 2.5 2.5 > 5 ^ 10 5 10 20 >20 > 40 >?> 160 * 40 80 160 320 * * * it > 20-40 CROC1DOLITE > 10-20 UICC > 5-10 U44 l' 11 22 > 2.5-5 1 <1 l 3 3 17 11 >.5-2.5 > 20-40 > 10-20 3 5 i CKRYSCrriLE UICC 7 <1 A > 5-10 UU 11 > 2.5-5 A > .5-2.5 8 15 it > 20*AO AAA GLASS > 10-20 CLUBS FIBER > 5-10 HU 14 11 17 7 5 iii > 2.5-5 7 > .5-2.5 <1 -*1 i > 20-40 AAA CLASS 10-20 SEPARATED >10jc1u" 5-10 HU > 2.5-5 1 > .5-2.5 83 20-40 ALUMINUM 10-20 0XID2 WHISKERS 5-10 4U4 2.5-5 t > .5-2.5 -4 1 v 1 2 2 5 13 65 tiit 3 17 18 10 23 12 * 44 1h8 26 1 5 2 "6 446 a 955 UCC 011771 4JA- IX TABLE 2 MESOTHELIOMA IKCIDE'iCS IH RELATION TO DISTRIBUTION OF FIBERS BY SIZE MODERATE INCIDENCE CROUPS (40-252 KESOTHELIGlAS) I UCC 011772 A "> 9 5 5 A3A-13 TABLE 3 ___ MESOTHELIOMA INCIDENCE IN RELATION TO DISTRIBUTION OP FIBERS BY SIZE LOW INCIDENCE CROUPS (20-51 KSS0TBZLIG1AS) I UCC 011773 A 1955? 43 A- MESOTHELIOMA TAB! IHCIDEHCS i^h u RELATION TO DISTRIBUTION OP FIBERS BY SIZE . ZERO INCIDENCE GROUPS (NO MESOTHELIOMAS) f UCC 011774 ; g K r~ o uOu 43A-5 We are particularly indebted to the latter Institution for the size separation of fibrous glasses, which were carried out through a series of millings and sedimentation of exceptionally fine-diametered glass fibers. All of the glasses were of the usual borosllicate type with mineral oxide contents previously recorded (Stanton ejt al. 1972). The non-fibrous aluminum oxide and aluminum oxide whiskers were commercial products obtained from the Artech Corporation, Falls Church, Virginia. These are single crystal fibers that are more than 99.5Z pure AI2O3. The method of counting fibers was previously described (Stanton et al. 1972). Samples of the materials suspended in Formvar were air-dried on glass slides and photographed at 1000 magnifications. From the photographs, 1000 consecutively counted particles were assigned to the 30 ranges of dimension indicated in t text-figure 1. Assuming that the particles in a given range were normally distributed around the mean size of that range, the total mass of all particles could be calculated, and the percent of the total mass occupied by particles in a given range or size compartment are the figures tabulated in tables 1-4. In the tables, the first and the second entry in each row entry of each row/'consiso of particles that are non-fibrous. The plus figures below the designated specimen indicate the extent of pleural fibrosis most commonly observed in the rats of each experiment. The rats are being observed for 2 years following application. All dead or sick rats are necropsied and histologic sections taken from the site of treatment and any other abnormal lesion. There is a limit to how precisely one can interpret results in terms of tumor response, because rats die at various times and from various causes during the 2-year period. A `i 9 5 5 J UCC 011775 43A-6 Nevertheless, from the present rates of mesothelioma development we can estimate the final incidences of mesotheliomas in broad terms of whether the incidence will be high ( i.e. ,>5OZ; table 1), moderate to low ( i.e.,<l40% but>5Z), or negative (table 4). Results and Conclusions: The data are arranged in 4 tables according to our preliminary estimates of mesothelioma incidence. In table 1 are the 5 specimens that have yielded a tumor incidence greater than 50Z. These are the UICC standard reference samples of crocidolite and chgysotile A, two samples of very fine fibrous glass with diameters of 3 p or less, and the aluminum oxide whiskers. All of these samples are composed almost entirely of fibers, and further have In common a predominance of fibers below 5 ju in diameter. The I AI2O3 fibers are of particular interest because they arg totally different from asbestos and glass, both in internal structure and chemical composition, yet their size distribution is remarkably like that of UICC crocidolite. However, one-third of the fibers are slightly longer and thicker than the crocidolite fibers and, since the density of is greater than asbestos, approximately one-sixth as many fibrous particles are present. The AI2O3 fibers are very durable and do not fragment to submicroscopic fibrils as crocidolite does. Whether this persistence of optically visible AI2O3 fibers relates to increased carcinogenicity remains to be seen. Tables 2 and 3 list the 7 samples of asbestos and glass which fell in the middle ground of carcinogenicity. \ These materials may prove more carcinogenic than we predict at present, but all show a lesser carcinogenic response than those of table 1. These groups show no single outstanding difference in fiber distribution from those of table 1. A ` 95OO UCC 011776 43A-7 Both extremes in the dimensional ranges of fibers are represented. For example, the two crocidolite samples show similar incidences of mesotheliomas, but one is composed almost entirely of long#largediametered fiber bundles while the other has less than half as many fibers all of which are short and small in diameter. Oils' explanation for this result is that fragmentation of fibers in vivo may play a role. The distributional array of fibers in the glass specimens would strongly indicate that carcinogenicity is decreased if fibers exceed 2.5 ^1 in diameter. Finally, table 4 lists 5 samples Including asbestos, glass, and AI2O3 which thus far have not yielded mesotheliomas. Except for the whole-fibered commercial glass, which is the type used as a vehicle in all experiments, none of these experiments with nonEibrous materials have progressed sufficiently to assure that no mesotheliomas will occur. However, the expected incidence in the remaining 4 groups i far lower than the materials in tables 2 and 3. I one analyzes the experiments in terms of individual types of material, some additional points are evident. Comparisons of the 4 samples of crocidolite (sections 1 of tables 1-4) indicated that none of the 3 extremes in fiber distribution yield as high an incidence of mesotheliomas as the more evenly distributed UICC standard reference sample. Either progressive pulverization to non-fibrous form by optical standards or preservation of the test sample in large bundles of fibers clearly reduces carcinogenicity. In considering the 3 samples of chrysotile (sections 2 of tables 1, 2, and 4), it is again apparent that the presence of A `i 9 5 6 ' UCC011777 43A-8 particles smaller Chan 0.5 x 1.5 4. (i.e., the clumps and masses of submicroscopic fibrils represented in the distribution of fully pulverized chrysotile) decreases carcinogenicity and that fibers with diameters of more than 2.5 and lengths of more than 80 n reduce carcinogenicity. In considering the 8 glass samples (sections 3 and 4 of tables 1-4) conclusions are not as easy. It is apparent that samples composed over 90% by weight of fibers with diameters of 2.5 or less are the most carcinogenic and as this diameter is exceeded by more and more fibers carcinogenicity is reduced-$j|Length does not seem critical here since the crude AAA fibrous glass applied virtually intact yield; more mesotheliomas than the same glass reduced to shorter lengths (section 3 of table 1 vs. sections 3 in * tables 2 and 3). However, reduced carcinogenicity in the glass samples may have resulted simply from reduction of the fibers to a non-fibrous form or to fused masses of glass of greater than 5 \\ in diameter. Final conclusions on this interesting series of sized glass fibers must await more accurate tumor-incidence figures. Nevertheless, it is certain that in the pleura of the rat, fibrous glass of small diameter is a potent carcinogen. Finally, the contrasting results with the fibrous and nonflbrous forms of AI2O3 reemphasize the importance of structure to carcinogenicity. These exceptionally pure, inert fibers composed of materials foreign to asbestos and glass seem to carry the dame carcinogenic hazard for the pleura as asbestos and glass. A i 95 c o UCC 011778 43A-9 It would therefore seem that carcinogenicity is in some way related to the presence of a durable particle of fibrous configuration in the dimensional range of optical recognition but presumably very near the limit of this range, and that carcinogenicity of asbestos, glass, or AI2O3 has little relation to the chemical composition of these substances or their potential contaminants. UCC 011779 A i 906 3 43A - 15 REFERENCES 1. Barrington, J.S. (1965) Chenical studies of asbestos. Annals of the Hrv York Academy of Science 132, 31-97. 2. Stanton, M.F., Blackwell R. and Miller, E. (1969) Experimental pulmonary carcinogenesis wtth asbestos. American Industrial Hygiene Association Journal 30. 236 - 244. 3. Stanton, M.P, and Wrench, C. (1972) Mechanisms of mesothelioma induction with asbestos and fibrous glass. Journal of the Hatlonal Cancer Institute. 49, 797 - 821. 4. Timbrell, V. (1970) Characteristics of the International Union Against Cancer standard reference samples of asbestos. Pnciuvocpnio-?lr.: Proceedings of the International Conference. Johannesburg 1969. Cape Town, Oxford University Press pp. 28-36. 5. Wagner, J.C., Berry, G.and Tirabrell, V. (1970A) Mesotheliomas in rats following the Intrapleural inoculation of asbestos. Pneumoconiosis: Proceedings oS the International Conference. Johannesburg 1969. Cape Town, Oxford University Press pp,216-219 6. Wagner, J.C.(1970B) The pathogenesis of tumors following the intrapleural injection of asbestos and silica. Morphology of Experimental Respiratory Cnrcinorenesls. AEC Symposium Monograph Series 21, Oak Ridge.Tennessee. Oak Ridge National Laboratories pp. 347-358. UCC 011780 A i 9564 f r Science center's 1973 in occupational health In 1972, a surge of activity in occupational health teas triggered by the Occupational Safety and Health Act. 1973 should prove an even more eventful year. In this exclusive interview, Dr. Irving J. Selikoff, a prime mover in occupational health, out' lines his plans for the year ahead. by Richard I. Snider Jr., Assistant Editor i Dr. Selikoff, in 1972 your study or. asbestos workers provided impetus for the development of a permanent OSHA standard an asbestos dust. Will you be completing a study of com parable importance next year? Yes, one on coal tar pitch and asphalt, which should have exten sive application, notably among roofers and steelworkers. It is a mortality study, similar to the one we did with the asbestos workers. We drew on data covering all 1 S.COO members of the Roofers' Union and charted cause of death in 3,000 con secutive deaths that took place from 1959 to 1971. Wc'rc also doing a study with the cooperation of the Printing Press men's Union on inks and oil mists which may be completed by the end of next year. Of course, there arc others. Tell vs a little about them. What subjects do they cover? Wc arc studying the health effects of pesticides and detergent enzymes with the International Chemie.il Workers', titanium with the Oil, Chemical, and Atomic Workers' and the Painters' Union, polychlorinated biphenyls with the Papermakers' and Union, cotton dust and carbon di sulphide with the Textile Workers' Union, cement and adhesives with the Tile Setters, epoxies with the Painters' Union, a bone disease called caisson disease with the Tun nel and Caisson Workers', and lead and other substances with the Ty pographers' Union. We will also be continuing our studies on asbestos with the Asbestos Workers' and the Tapers' Union. Dr. l.-.ini? J- Selikoff joined the fac ility of Ml. Sited in i')4l and contin ues his tenure in the Medical School ns a professor of medicine and commun ity medicine, in IVSS. he received the Albert Ijoker Award jrnm the Amer ican Public Health A suteiaiinn jor his studies on luhcrctthytix. Witen Mt. Sittiti formed the Environmental Sci ences l.aiunatorv in I Dr. Selikoff was appointed director. Doctor, what are your thoughts on the present permanent standards for asbestos promulgated recently by OSHA of 5 fibers longer than 5 mi crometers long per cubic centimeter of air, dropping to 2 fibers in 1976? I call it the 20-million-fiber stand ard. That is how many asbestos fib ers a worker can inhale during a workday if the air contains 5 fibers per cubic centimeter. I he Job Safe ty Law reipiires OS'ilA to assure as far as is practicable that no worker A 1955S December 1977/OCCUrAIIONAl HAZARDS 39 UCC 011781 I m.' Dr. Irving J. . Selikoff (right) discusses his health targets for 1973 with Occupational Hazards' assistant editor Richard Snider in his office at the Environmental Sciences Laboratory in New York. suffers ill health from his work en posed to the agent we are studying: Cooperation from the workforce 1 vironment. This has not been done and all our studies are epidemiologi is sometimes essential for a success Yi under the present OSHA standard. Our study indicates that, if past cal, that is, based on large popula tions of exposed workers. This is ful study. Working wifi the labor union can usually guarantee that co experience is an index and if the w-herc the labor unions can make a operation. situation remains the same 95.000 significant contribution to the study Finally, and perhaps most im of the 250,000 asbestos workers in of occupational medicine. The labor portantly, we work with the labor the United States today will die of unions are large; built-in control unions because this is where the ac occupationally related cancers. Be populations allow the study of a tion is. The initiative for the study fore the standard drops to 2 fibers in broad spectrum of health effects of hazardous substances in the work 1976, perhaps another 100.000 new from exposure to a substance. The environment is coming more and workers will have been exposed to unions cover a large geographical more often these days from labor asbestos dust. If there is no chance area. A company usually concerns leaders. we can expect that 25.000 of them itself only with its own employees, will die of occupationally related and is thus often limited in popula Are the workers as enthusiastic os cancers. All of these deaths are tion and geographical range. the'labor leaders? Isn't there consid unnecessary. The unions have long-term health erable conservatism on their part, a There is a 20-ycar or greater information about their members, disinclination to cost company man lapse between the first exposure to including workmen's compensation, agement such targe sums of money asbestos and the onset of asbestos- records, post retirement health in that their jobs might be at stake? V induced cancer. If we want to con trol this disease in the year 2,000. we must start now. The case, however, is stili not dosed. The Industrial Union De partment of the AFL-CIO has tiled petitions and briefs in the U. S. Court of Appeals in Washington D.C. to contest the standard. formation. and death certificates. Companies, on the other hand, usu ally have records for only as long as the worker was employed by the company. Union records, in some cases, go back as far as the Civil War, thus enabling us to trace the health effects of new materials and new processes from the very first day thy came into use in the work Yes, many of them feel that wav. and I understand their position. For older workers. leaving the job does not mean leaving the dust. They carry it with them in their lures. For them, the potential gain is lim ited, and their job is precious. For many younger workers, especially those working in small communities, there might be no other jobs avail f. How docs it happen that so many place. able to them. I Can understand why rJ *i of your studies ore done with labor unions? The unions arc usually able to follow a substance in process from raw materials to finished product, a such workers might choice a 'teadv job over good health and a K-neer life. This is not conservatism bu: All our studies arc clinical, that process often spread over many realism. is. based on workers who arc ex- companies and industries. According to the law, however. 40 OCCUfMIOHM IAZAeOJ/Dc.mt>or 19/2 A 1 956o UCC 011782 lory, identifies mineral particles with a polarizing microscope. Environmenlol engineer Duncon Holoday demonstrates a Geiger counter. employers are required to provide a workplace free from recognized hazards. Workers should not have to choose between health and a job. Besides your health hazard studies, do you coopercte with unions on any other projects? Yes, we conduct courses, educat ing workers to recognize, avoid, and eliminate the hazards in their work place. In 1971, we ran a 5-day course on occupational health hazards for 75 trade union representatives. We ran a course for 50 shop stewards in the Textile Workers Union of America on occupational health haz ards in the manufacture of viscose fiber and film. Later this month, we'll begin the first of three sched uled courses on occupational health hazards in the asbestos industry. Each course will he attended by 50 shop stewards. The course will be given in New York this month, and later, it will he given in Si. Louis and Los Angeles. Docs industry ever participate in your occupational health projects? Wc work with industry whenever we can. Jolms-M.uniile Corp. co operated with us in our study of asbestos. The Printers' League is cooperating in the study wc arc con ducting with the Typographers' Union. Industry experts are often fea tured lecturers or panelists in our health hazard education courses. Johns-Manville supplied lecturers for a graduate course on asbestos which we ran for doctors at Mt. Sinai. FMC Corp. helped us in the course we ran on viscose fiber and film for the Textile Workers'. Industry is also a source of some funding. One student on our staff doing research on asbestos is sup ported with a Ford Motor Co. grant. Mrs. Samuel Rosen demonstrates au diometry at a Mt. Sinai conference. What are the other sources of your funding? They arc many: Our Environ mental Sciences Laboratory has a budget from Mt. Sinai Hospital. We also get funds front the National Institute for Occupational Safety and Health, the National Institute for Environmental Health Sciences, the Environmental Protection' Ag ency, the Department of Air Re source!! and Health Research Coun cil in New Yoik City, the American Cancer Society, business, and labor unions. Or. Solikoff nmt.es liis point wun one Onion leader attending a conference. A 10567 Dtombtr 197?/OCCUfATlONAl MA7A90J 41 UCC 011783 :< . .fs 3 4 Research minerologist Anne Mackler operates the electron microprobe analyzer. Ml. Sinai's Environmental Sciences Lab' oratory is one of the most extensively equipped in the country. -4 . : *r.:! Our costs this year were approxi mately SS00.000. In 1973. that specializing in occupational medi cine. The doctors chosen wiil spend take it you have some reservations about the efficacy of threshold limit figure will probably rise to SI rnil- one year in residence with a major values and instrumentation far en lion. labor union where they will come to forcement of OSHA health standards? grips with real life problems of .? ; Are tome funding sources, such os 1he labor unions, drying up? workers and learn to speak their language. Candidates have already I do, indeed! When you consider that there arc only 44 industrial been lined up for the AFL-CIO, hygienists on OSHA's staff and that -i 'iys- A ! No, I sec no indications of that. The labor unions have never been a major source for funds, and I don't think they should be. We're not hurting for funds. If a study is important, funds arc us Textile Workers', Oil. Chemical and Atomic Workers. The residency will be supplemented with classroom work and ward, laboratory, and field training under the supervision of Dr. Harry Hcimann of our staff. they have to cover 4 million work places, you suddenly appreciate that it's mere idle chatter to talk about TLV's and instrumentation for en forcement. Wc asked 11,000 members cf the vj ually forthcoming. Our primary need is manpower. There are so Asbestos Workers Union it they had ever observed a dust count being many studies so urgently needed, How would you rate the perform taken in their workplace. Averag but so few hands to tackle them. ance of NIOSH in occupational ing the total response revealed that hcolth? workers had observed oniv 1 dust count for every 20,000 manhours How large is the staff here at the worked, meaning the individual V Environmental Sciences Laboratory? Very high. I know many of the worker had seen a dust count being -'.N> .1 Wc have 49 scientists on our staff. men working at NIOSII. They arc well qualified and do excellent work. Unfortunately, they are tied down taken only once every ten years. I think wc need less discussion about dust counts and more discus by underfunding. sion about engineering controls. I Are you doing anything to attract ant confident that industry's re people? sourceful engineers will tind some The recommendations attached to means of control if industrial lop Next year, we hope to begin a your study on asbestos playeil op the managements will give tlnm that residency program to train doclois importance of engineering controls. I assignment. U O OCCUfAIIONAt MA2a*DS/0. 1WJ A 956G UCC 011784 Occupational Health & Safety Letter, January 8, 1973 AUTOMATIC BAG OPENING STATION FOR ASBESTOS FIBER DEVELOPED: Johns-Manviile Corp. has reported the development of a completely automatic fiber b3g opening station to protect workers from the hazards of asbestos dust. Tire development was announced by Edmund M. Fenner, corporate director of environmental con trol for J-M but representing the entire asbestos industry at the 23rd annual Governor's Industrie! Saiety Conference in Olympia, Wash. He explained that J-M is currently testing the design of the station. When it is fully developed, bags of raw asbestos fiber will be cut open and disposed of, with the fiber being removed and introduced into the manufacturing process without exposing any employee to significant levels of asbestos dust. Fenner spoke of the importance of effective dust control systems, as well as regularly sehcdifled industrial hygiene surveys and properly planned plant,'equipment maintenance programs. Asbestos fiber is widely used in the manufacture of floor rile, asbestos-cement pipe, brake linings, clutch facings, roofing, siding and flooring, insulation, textiles, paper, felts, plastics*and fireproof clothing. Nearly 750,000 tens of asbestos are consumed each year, according to the Asbestos Information Assocsation/North America. a i 9563 UCC 011785 c<z: 0'CU>f 'AIA/NA MEMBER COMPANIES George Barge E. C. Bratt H. Randolph Brown J. D. Christian A. H. Fay W. E. Gatewood A. R. Hooker J. H. Marsh C. G. Morgan C. A. Neuman J. L. Rainey J. W. Rawlings Wes Sauerland Kurt Schwarz F. J. Solon, Jr. J. R. Stetson S. D. Weaver Paul Weiner J. K. Whittaker L D z?< / o- / Atlas Asbestos Company CV H. K. Porter Company, Incorporated / Uvalde Rock Asphalt Company Cassiar Asbestos Corporation, Ltd. National Gypsum Company Certain-teed Products Corporation The Flintkote Company Raybestos-Manhattan North American Asbestos Corporation Kentile Floors Incorporated Amatex Corporation Union Carbide Corporation Jim Walter Corporation Supradur Manufacturing Corporation Johns-Manvilie Corporation Congoleum Industries, Incorporated Cement Asbestos Products Company GAF Corporation Nicolet Industries, Incorporated AIA/NA ENVIRONMENTAL CONTROL SUB-COMMITTEE E. M. Fenner W. J. Dickson W. Fassuliotis Ralph Lanz , John Myers ^ Wes Sauerland Ike Weaver Frank Zimmerman - Johns-Manville Corporation - Flintkote Company - GAF Corporation - Nicolet Industries, Incorporated - Union Carbide Corporation - Jim Walter Corporation t Raybestos-Manhattan - National Gypsum Company I AIA/NA LEGAL COUNSEL Joseph W. Burns Burns, Van Kirk, Greene & Kafer AIA/NA PUBLIC RELATIONS COUNSEL Tony Federico C. L. Forbes Mike Isser Jack Steinberg - Cunningham & Walsh " -" " " AIA/NA ENVIRONMENTAL CONTROL CONSULTANT C. L. Sheckler ,, A ;957C UCC 011786 CC: A. E. Alpine G. M. Armstrong James Armstrong I. C. Campbell Richard Carter C. Nelson Codding A. A. Cross Hugh Davson-Walker Mike Donovan Doris M. Fagan Lyman Field J. A. Gossip Joseph Hall Stephen Holmes Wilfred Howard Michael F. Howe Ellsworth F. Marriner, S. Monoky Art Neilson P. V. Pelnar, M.D. F. L. Pundsack Ivan Sabourin Martin Sendecki George P. Vogel Hans Weill, M.D. G. W. Wright, M.D. Les Kaas Bruce Phillips M.D. - Certain-teed Products Corporation - Amatex Corporation - Bendix Corporation - Q.A.M.A. - Johns-Manville Corporation - Jim Walter Research Corporation - Cape Asbestos Company, Ltd. - Hill & Knowlton (UK) Limited - Johns-Manville Corporation - Asbestos Textile Institute - Rogers, Field, Gentry, Benjamin Robertson - Q.A.M.A. - GAF Corporation - Turner Brothers Asbestos - Asbestos Information Committee (England). - Turner & Newell - Johns-Manville Corporation - Certain-teed Products Corporation! - Fireman's Fund American Insurance Company - Institute of Occupational & Environmental Kea - Johns-Manville Corporation - Johns-Manville Legal Counsel - Congoleum Industries Incorporated - Ertel Engineering - Tulane University - St. Luke's Hospital - Certain-teed Products Corporation - Certain-teed Products Corporation UCC 011787 ft 1 9 5 7 1