Document g2gbDpm16NVZdV88Y6nY1vY9

VICE ON statement of HONORABLE BARBARA HACKMAN FRANKLIN CHAIRMAN, CONSUMER PRODUCT SAFETY COMMISSION OSHA'S PROPOSED RULES FOP. TOXIC SUBSTANCES POSING A POTENTIAL CARCIXOC5MIC RISK WASHINGTON, D.C. MAY 16, 1978 I appreciate the opportunity to subnit soma brief, personal views on OSHA's proposed rule for toxic substances posing a potential carcinogenic risk to .workers. At the outset, I want to salute OSHA Administrator Eula Bingham and the agency staff for the tremendous amount of work and effort which led to today's hearing. Also, I want to call special attention to literally the volumes of written and oral comments that OSH.A's proposal has generated from interested individuals and organizations. I think this indicates the great concern all of us have in this matter. I What we are addressing is but one part of perhaps the most important health and safety issue of the decade.:., how this country will go about protecting the public from the growing number of substances potentially capable of causing cancer. The OSHA regulation focuses on protection of people on the job, but the significance of the proposal stretches far beyond the workplace. For example, my own agency, CPSC, is proposing its policy and set of procedures to help protect consumers in and around the home. Other agencies, such as FDA and EPA, are concentrating on other aspects of the problem in keeping within their missions and the laws they administer. qAF 15834 2 For all agencies as well as countless companies tin;'; the public at large, OSHA's hearing is critical. Many or the underlying issues -- especially fundamental, scientific concepts and the social and economic impact of regulating in this area -- arc matters of great mutual concern and interest and will be discussed here for the first time in great detail from a variety of perspectives. While some differences in the basic approach of each agency exist, I believe that all Federal activity must always be as responsible and consistent as possible. As a general rule, in other words, each agency must arrive at solutions the government can live with, business can live with and most importantly, the American people can live with. To me, this underscores the importance of this hearing and the work of the Interagency Regulatory Liaison Group and CEQ's Toxic Substances StrategyyConmission. Eventually, the Federal government as a whole, as I see it, must move toward a national cancer policy or a set of principles which guide all of the research and regulatory efforts in this area. The heady problems associated with the causes and control of cancer truly are shared ones, and it seems to me that it serves the broad public interest to approach them as intelligently as possible. So it goes with the solutions, if they are to be sound, equitable and lasting. GAF 15835 3 This is why I will continue to urge formulation of a national policy on carcinogens with the weight of the White House behind it. The public is currently confused and cynical about cancer issues. Therefore, although government must take the lead responsibility, the policy must reflect and involve the diverse concerns of the public. Such a policy should articulate -- so that everybody will know -- the posture and program of the Federal government as a whole and the guiding principles behind it. At a minimum, I believe such a policy must address issues including these: the definition of a carcinogen; information needed to regulate cancer-causing substances; the tests that should be used, how they should be conducted, and how the results should be interpreted as well as the extent to which factors other than the public health should be considered. Flexibility must be integrated into the process so that developing scientific knowledge can be applied and so that the individual agencies can perform the jobs that the President and Congress expect. Perhaps most of all, such a policy must clarify the magnitude of the problem, the need for adequate public protection and for timely, intelligent and informed action to achieve it. GAF 15836 In summary, let me reiterate my support for the trailblazing OS HA has done. Hy their actions, OSIfA and other agencies, including CPSC, are recognizing that the central issue of whether exposure to carcinogens should be regulated is resolved. Many, many important questions of law and public policy remain, and I will be especially interested in the viewpoints and information of the public on these matters during this hearing. I. I l GAF 15837 1 > 't wASnirjc^'cirj. o c ~-..?2v April 4, 1978 Mr. Tom Hall Hearing Management Officer Occupational Safety and Health Administration Department of Labor Room N3635 200 Constitution Avenue, N.W. Washington, D. C. 20210 Dear Mr. Hall Enclosed are my comments on OSHA's proposed rule on identification, classification and regulation of toxic substances posing a potential occupational carcinogenic risk. I would appreciate their inclusion in the public record on this matter. ' Sincerely, Enclosure Barbara Hackman Franklin Vice Chairman I ................... .... 1 " 11 ................................* ` ,.i 4 >" ' 1 `-| 1 1 " 11M W GAF 15833