Document jy2Djrd7Q2Kkyn3ejL12JDJk5

V\J , >-Ar <2.' :V-r t B.13.1373 Heaprsnduni Review of Utter of Dr. H.C. Lowiasoha ad Dr. S. Bolaoa to Dr. I.J. Bellkoff, July 13, 1373. Ssawpia Dr. Sollkoff'a roaarka at tho Aaorieaa loduatrlal Hyglone Coaforoaco, May *1. 1373, aa recorded and transcribed by undisclosed sources and subaltted by Dra. Lovloaohn and Ho1ms. CoMlttoo oa Hygiene Standard* of the British Occupational Hyglena Society. Abb. Oceup. Hyg. 11:47-03, I960. H.C. Lowlaaoha. The ilodlcal Surveillance of Asbestos Workers. Roy. See. Health J. 33:63-77, 1972. 8. Barry. Rygleae Standards -- Theory and Application. Lyon, Oct. 3, 1373, Paper 23. S. Bolaoa. Criteria for Environmental Data and Bases of Threshold Lialt Valaoa -- Environmental Data in Industry, Lyon, Oct. 3, 1372, spar 30. (reference to nwbered paragraphs in Leviaaoha-HolMS letter). Tr.j - > 1(a) The paper "...ess not intended to Justify or verify the BOBS standard." Mere did 1 say it was so intended. __ A-- p-i-V-'* * 1(h) "The results presented in Id's paper were preliminary results." . " -f V' - * -TO? ; : It is possible that you will have further findings but at the tine ofaii*J>rosontatloa only those were available that you / I, aaddefload in four paper as ibllovs: IpeSre" be',!j6b .ttb wales }gd3lT toaasstbestos. %tathe previous report it liological but. s- -yt e expressed." I fail .ton the implied eonplilat. Bovhere did X was Interested only in your data. * ;.vww .tv *? ................ LABORATORY ' - jeagsa 4.: :* s'' I(i) You ittu that the populations reported by Knox and Ml *ore not identical nor were "the very large najorlty" "ocaon to both surveys." X would bo Interested in data to support this assertion, with reference to the employment categories specifically referred to bv r.v in nr presentation. i.e., those 1,0-19, 20-29 and 30-39 years from onset, and re produced in ay tables (see 3(a)]. These were the groups Is which radiological changes were seen, and to which reference' was sade. (Document A, pp. 10-11.) The thrust of ay discussion, and the contrast to which X. pointed, bore on the Individuals x-rayed by Knox (Document B, p. SS) la I960. All of these individuals were at least 10 years froa onset and, unless no longer working at Turner Bros.( verb in the 1970 groups x-rayed by you. Do you contend they were not? Xf so, please explain. X made no issue of individuals 40* years froa onset, nor were they included la the graph (see 3) since they had begun work before 1933, and were not included in Dr. Knox's report. *(b) Insofar as you would have preferred that X had designated the additional individuals x-rayed by yon as "quality control and research staff" rather than."office workers" X can only plead the shorthand of an extemporaneous presentation designed to fit a United tine allotment. Incidentally, my experience with 0.8. research staffs is that they do spend a .good "deal of time la offices. 3(a) Yon complain that X stated that. Kaos reported on 913 men with at least 10 years exposure. You misquote me. Uy exact words., wore: "Dr. Knox had oxamlnod only mem in ths scheduled areas 1 -- that is, the production areas, 913-, whereas Dr. Lewinsohn V. included all employees...." (DoetniratA, p. 10.) Ths figure - ; 13 was gives to compare a production area group with . the larger population (1,297) x-rayod by you. Bo statement was by me that swch a sunber was in the 10 rear or ever groups. - l;1iiy^ow^s to tin''Knox*s findings 'word' specific' aodv'->-.;; C. X showed a slide; which ertscatod the precise data ythCitjhftn la the paper published in 190B : ' V r ir "' y 5*?-4- the dcii(Mtiou "10 to IS fibers per ec" and 3 to 4 fiber* yor c" were derived froa Ur. Berry's table la 1973 (Document D, p. 11), Be gives the* as 10.9 to 19.3 fibers/ca3 sad 3.4 to 4.1 tlbers/ca3. I believe ay reference Is accurate. 3(b) by use of the phrase "...could have been asbestosIs" (Doeunent A, p, 8) was based upon the coluaa heading la the 1968 paper (Docuaent B, Tables 1 and 3, p. 53), "X-Ray chaages possibly ashes tot1c," and therefore s.eas entirely faitaxui. 3(e) You will note, too; that ay tables listed 390 aea with nor* and than 10 years, exactly as reported la 1968. 4(a) Those wore coopered with the results In those workers x-rayed by you la the saae general eaployseat categories, 1.*., 20-29 .year*. 30-39 years, 40* years" fro* first oaployaeat." This 1* admittedly not absolutely Identical with your predecessor Dr. Knox's " years eaployed" but, if anything, your employment categories ("years froa first eaploymeat") could not have re flected aore than Dr. Knox's ("years eaployed"). It could have been leas (If soae workers had periods out of work), but not aore. Therefor*. If anything, your x'-rays should hsvo shown less disease than Dr. Knox's, by eaployaent category. 4(b) You eoaplala that the ten "asbestosIs" was used on the graph. This word was used by Knox while you used the ten "pulmonary fibrosis." Ve therefor* had the option of using either. Per haps you aight advise a* if you think X was Incorrect in uslag Dr. box's "ashestosls," sad if you believe it is stretching to so label your "pulmonary fibrosis," when you describe such x-ray fladings' la wortsrs eaployed la ss asbestos factory ^ for 30, 30, 40 or aore years. Z see* to rsaeaber aa old taglipb saying, to the effect that clrcunstantlal evidence is very strong, aa whoa one find* fish la -the aftlk.. You say that you did not stteapt to calculate fiber years/ec. X did aot say you had. X did show a graph prepared by pr. Yilllaa J. Rlcholsoa of our laboratory ooapariag your x-ray findings with Dr. Knox's uslng aa overall ayerage cuaulatly* f for thOOatlr* population.. The'.'exposure. experience net tsfcsa ouVofthla' air but was* derived,;Itcml th*~v*ry ^v rrhroa. dust da|a aaalyslstpr*seat^ by ttr.' O. ^' ns la tyoa on October 3, 1973 (Docuaslt D)iv3fiee data" were 'as Ithd .latest available, Unfortunately, .you aot pre- . asbestos estiietei i vr^ihe dist levels eated at . -Tor tlvi'ixposures prior to 4.30.1 . _---------- -----------------------lapnsui was added 33.8 fib*rs/co-y*ars. tWA was obtained; by averaging the dust level data listed la Table 4, page BT, * ,*& of Document D for tho flbcrlztng, carding and spinning depart* nents and multiplying by 4.5 years. Ten year average oxposuros were obtained by averaging the data in appropriate 5 yoar cate gories, weighted by the number of men working In 19G6, Because we had no way of associating observed x-ray changes with in dividuals In high and low 10 year exposure categories and in order to be as conservative as posslblo, the dust exposures assigned to groups of workers wero those of the highest ex posed workors although 1/3 to 1/2 of the individuals repre sented by e-ui. point wero exposed at levels 1/3 less. , 1 The estimates of the nissber of individuals affected were also as conservative as possible. All questionable parenchymal x-ray changes and all pleural changes not consistent with asbestosls were considered as negative. As can be seen by comparing the graph with your figures 2 and 3, our conservative approach has resulted in the graph showing less x-ray abnormality than do your figures. Z would appreciate either reworked or new dust data to go with your x-ray results and will then prepare another graph. In the meantime, we will have to use dust data presented from Turner Bros, by Dr. Holmes in 1968 (Document B, p. 57) and by Ur. Berry in 1972 (Document D). Since Dr. Knox included in his recorded x-ray changes pleural abnormalities as well as parenchymsl disease, it may well be that there were even fewer than 8 eases, of those he reported, with only pulmonary fibrosis. The 1968 paper, does not cake this clear. If this were so, then the contrast with your 1970 "pulmonary fibrosis" category would be even greater and the discrepancy even more puzzling, since we conparad all of Dr. Knox's "possibly ssbestotlc" x-ray changes (Document B, p. 55) with your core limited category "puloonary fibrosis." A further point Is In order. The 80HS paper la 1963 was con cerned with earliest evidencs of dlssaso resulting froa asbestos exposure. (Document B, p. 50.) Indeed, It deemed It sdwsatsgeous to so consider basal rales, since these could occur before x-ray change. Tou state you used "the 0.I.C.C./IL0 classification" (nislabeled; it is the IU> U/C classification!) to analyse your radldloglcal findings. Tour appropriate use * of this international x-ray classification system rather than a personal ona has surely allowed you to approach the goal of the use of the earliest demonstrable effects duetto asbestos," as the erlterloa tor "asbestosls." (Document C, figures sre llkeiy to Itsidust.' tba reported f** with* sis to reflect what sctualiygxlsta among workers st tbs Turner Bros." Asbestos C6., Ltd Basal rales. 1 made aio reference to basal rales since your peper did not report on these (Decuaont C, pp. T4-TS) and -.f .. -> St*.** ?$&. v-; VT-V* .: >- comparison of 1966-Knox and 1970-Lc-vinsoha was thus not possible. Parenthetically, neither did I compare pulwonary function findlacs. which were reported by you but not by Knox (Document C, pp. 73-78). (a) Did you have any cases recorded by you as "pulmonary fibrosis* a see which did not have characteristic asbestotic interstitial 4(b) fibrosis if they later cane to post-mortem.7 8(b) You state that I 1snored "...the fact that the number of eases of asbostosls in 1948 among 333 employees (men and women) ex posed for 10 years or more since 1933 in Rochdale and still____ _ employed, was 1.12% (l.e., 4 cases) as compared with ilerewether's finding of 44.4% (i.g., 39 cases) among 133 workers exposed 10 years or more in the same industry in 1929. This lower in cidence has occurred in spite of the fact that the Pneumoconiosis Nodical Panels are better equipped to diagnose asbestosis than Nerewether was." `&e X charitably made no reference to this observation of yours 'contained in Document C, Table XX, p. 71), since it was such an obvious error: indeed, I regret that you have again ealled attention to it. The Pneumoconiosis' Panel cases were new cases first diagnosed in 1968; rewether's data gave the results of a study of the prevalence of asbestosis among a group of workers in 1929. One should not confuse annual incidence of disease, with its prevalence. (Your Table II follows.) (ml wgfcmfl i Tamm B f 1) 1961 (aOft as i m UJW) i wttdsdm qfl gas.TBS." 38 - MaeT 348 the cooteats of a "private correspondence" that =ri-n the.* .l.MoiSy-ia- sslhc ,4Ui;niri fereaee >8, p. n), they bad not yst "appeared in prlet tar bold therefore not readily study than.* lOH'o'-v 8nIK` . i, >A CSaTURNCR gr& A NtwAa enoiUNTEO Industrial Products Ltd i% mm mViaI--S'SSi- HO/fcV ' 12.7.75. Professor Irving J.Selikoff, Mount Sinai School of Medicine, Fifth Avenue end 110th Street, m YOBX II 10029. * TJ.S.A. Peer Professor Selikoff, Vo have recently received a transcript of a tape rooordii^ of your address to the Anerican Industrial Bygiaae Conference in Boston on 21st Kay,1973 which was sent to us because of its references to our work. If the coggr enclosed herewith is a true representation of that and the graph shown by you. it tell*you that find your assumptions and conclusions to be extrsnsly misleading. the case aade at the end of your paper appears to rest on the fact that the data which fooud the basis .of our Hygiene Standard* was scanty. You then atteapt to extract data fro* the Figaros in KX'i publicatioona*r in onrder to show a discrepancy between the original data and that# figures. Ve are astonished at your keying obawmicistsd the contents of a private . orzospondenoa to the neetln* which you addxessed without having obtained our Ve areals very displeased at yblehyoahsyo usedths informationwe provided in what sisne to us to be a political oanpalgn la at discrediting oar Bygione Standard*or asbestos. ~ ths isplioation that lie 2CL publication allows iy ths vaalidd!ltr of the BOOB Standard and art *t. a coooliusionis have i ths Bus data reasona i* ' -vv verify the MBS"ii refs is thlspger't imsc rmaa* aialtat--t^eisSiits&d in%Kb!*l!iBasiear vsert>esylleereaarlllllyyiinaataiytsdresults" that *froa the infoasatien ourrently available only tentative opinions osn be expressed Ve /eont. -oafl -rfkl'fr -T- t-* r *v 'j . r. surprised therefore that you have been able bo rood far aoro lato tho incoaplete picture preeented than tho author was able to do or latoadod to le>. Tho populations roportod by Khox and HC^wort not Idoatleal nor war# 'tho vary largo majority' Of asbostos workers 'eooson to both surveys', as you suggested. 'Offleo poraoanol' voro not included. Tho population otudlod by nOL conslatod of vozkoro In tho roeoenlsod asbostos areas, together with aalntenanee, quality control sad rosoareh staff* Knox roportod on 290 son (not 915 so stated by you) with at loast 10 years exposure sines 1st Januaxy,1933 when tho Asbostos Industry Regulations 1991 took effect, and who wore still In tho Coapany's eaploy on tho 50th June *1966. BCL on tho other hand has analysed tho X-rays of a such larger population (1,287) as of Bovekber,1970 irrespective of date of first sayloyattatt sobs voro la fact first eaployed before 1st January,1933* Knox eub-divided his population aooording to ouanlatlTo exposure vfasroas BCL's vas sub-di by decades elapsed slaos first exposure. Irrespective of the actual nosher of years exposed. In view of : these basic differences sad ethm^ddeh we will^-vS; derived the relationship between emulative exposure and percentage of individuals affected on the graph which you shoved (copy attached)* the graph is obviously nisi aiding as BCL at no stags asbsstosis*.  . -3- 6. Cont/......... BCL on the other hand attempted to enalyoe Ms radiological findings according to the DICC/i.LO classification! an entirely different set of criteria, and took no account of the clinical picture as a whole. 7. The BOUS eub-cocnittee decided that basal rales were the 'key symptom' s^nce all the nen with X-ray changes, by the Knox criteria, had basal rales, but some with basal rales had no X-ray changes.^ ' HCL points out in his paper that he has not yet attempted to correlate physical signs and X-ray changes. 6. . Ve are obliged to point out that the use of the words 'pulmonary fibrosis' by HCL in his paper may have misled you, as they were used to describe email opacities which prior to the advent of the UICC/lLO classification may have been regarded as consistent with flbrotio changes* The use of this term does not allow for sub-division Into profusion and typo of opacity as Is now possible with tbs UICC/lLO classification. for simplicity In presentation, BCL grouped all cases showing evidence of these ehang-s together, irrespective of severity. Knox only included X-ray changes oonalatent with the clinical diagnosis cf ssbsstosls. It is net possible to say, frm the data that BCL has compiled, bow many persons would fulfil the criteria for a clinical diagnosis of asbestosis, and to attempt to illustrate thee# two very different sets of data on the sens graph is simply not psmisslbls. ' fbo ollnleal significance of tbs radiological changes observed t os yet. bo defined. V" .. . >->? '&-V i tod spptor to bavo ignored eosplstely the feet that the amber of cases of asbestosis la 1966 among $3$ es^loyees ..(men and woosn) nursed for 10 ysors or nors sines 19531a Bocbdale and still taployed, waa 1.12* (l.o. d eases)) as oos^ared with Ksro^ethsr's - this lower Incldsncs has occurred spile of the (lef that tha resume oonloula Ksdioal Panels ere better\ equipped to diagnose asbestosis than Kerowsthsr was. V In addition, during the rears {mediately following 1933 there still was substantially greater exposure in certain Jobe than in nors recent tines. /ooat Xn view of your comments and our provlous correspondence we should Ilk# t- rtrici you that w are in the process of reviewing and bringing up to date all the available data, and bops to presoat it for publication in the near future* Dr.Holmes' remarks at Lyon were never Intended to suggest that the BOliS Standard was not stringent enough* The BOOS Standard is 100 fibre years/ce and therefore application of a 2 f/eo limit for poriods of less than $0 years has the effect of providing an ample safety margin. The SOLS Sub-corralttee, of which we are both embers, recently reviewed the Hygiene Standards for Cfarysotilo Asbestoe^ in the light of the latest available data and recommended that no change be made at the present time. Ve are forwarding a copy of this letter to the President of the American industrial Hygiene Association, the Chairman of the ACQXH, the Director of HIOSH and also tbs Asbestos Information Association of north Aasriom in view of their obvious interest in this important subject* Tours sinoerely. I.WMSCOf, H.S. l.Ch* B.Z.B* Chief Hrtical Officer*