Document jy8oDQ6ME8m33agd5eoXjYzNR

Asbestos Information Association ' .North America Third Annual Industry Government Conference Sep tem b er 8 - 9, 1976 ASSESTDS INFORMATION ASSOCIATION. CONTENTS Foreword Speakers (in order of presentation) Andrew W, Briedenbach, Ph.D. Assistant Administrator Environmental Protection Agency Hans Weill, M.D. Professor of Medicine Tulane University School of Medicine John J, Sheehan Director of Legislative Department United Steelworkers of America, AFL-CIO Monitoring Asbestos Dust Panel: Moderator: Harrison B ,, Rhodes, Ph.D, Union Carbide Corporation Stephen G. Bayer Instructor, Division of Training and Manpower Development, NIOSH Robert D , Soule Vies President Clayton Environmental Consultants, Inc, Stanford K* Christian Industrial Hygienist The Bendix Corporation OSHA Presentation: Grover C, Wrsnn Chief, Division of Health Standards Development Charles A ,, McClure Supervisory Industrial Hygienist Compliance Programming 11 32 42 43 45 51 61 71 80 THIRD ANNUAL AIA/RA INDUSTRY-GOVERNMENT CONFERENCE September 8' 9, 1976 Attendan.ee List Edwin W. Abbott John Adams Sarkis G. Ampian Joseph Artabane, John Autry Esq. Trygqve Baak George Barge Richard Bauer Stephen Q. Bayer Horace Beasley Keith A. Boddert Colleen Boland Ernie Bratt Andrew W. Breidenbaeh, Rh.D. R. C. Breiner L. Elliott Bristol Morley Brownstein (borne Butt F, T. Byrne John Cain A,1 Callahan William Campbell Richard Carter Ramon p. ce.sta John H , Chidester Bob Chiostergi Stanford K. Christian Phil Cieslak William C. Clark Robert A. Clifton Jim Cloney Gordon A. Coats Mitchell Comins Walter Cooper Joseph R. Copeland. Alex Cross'"'" Allan Daly Richard T. Davis Russell A. Dawson Ginny Detgen Thomas A. Dougherty Ed Drislane Air Transport Association Westinchouse Electric Corp, Bureau of Mines Cadwalader, Wickersham & Taft Johns-Manville Corp, Cyprus Industrial Minerals Co. Atlas Asbestos Co. National Gyosura Co. NIOSH Cement Asbestos Products Co. OSHA AIA/NA Staff Southern Asbestos C o . Environmental Protection Agency GAF C o r p . American Biltrite, Inc. Dept, of Consumer & Corn. Affairs (Canada) Raybestos-Manhattan, Inc. 3M Company. 3M Company Nicolct, Inc. Bureau of Mines Johns-Manville Corp. Eastern Airlines Int'.l Airport Brunswick Fabricators, Inc. Textile Fiber Dept. - Dupont Co. The Sendix Corp. Nilfisk of America, Inc. Ashen-Hill Ltd. Bureau of Mines GAF Corp. Caleveras Asbestos Ltd. Auto Friction Corp. Johns-Manvilie Corp. Pfizer, Inc. International Asbestos Information Conference Certain-teed Corp. Frank C. Frantz 6 Co. "Job Safety & Health Report" AIA/RA staff Certain-teed Corp., President - AIA/NA Friction Materials Standards Institute A~1 Maurice Eastin Philip E. Enterline, Ph.D. Doris Fagan William Fassuliotis A1 Fay Erich M. Fexerabend Paul Filteau J. J. Finnegan ^ershon Fishbein Frank C. Frantz G'uy G. Gabrielson, Jr. Earl o-agan Martin Garber , J r . James Gilmore Joseph Goldfield Robert A. Good, Jr. Robert M. Gordon Charles Grossman George P . Haecker Jerrv T-lammang Allen m . Harvey Ronsr Hawk, Ph.D. Michael Helton Clarence A. Herbst, Alton H . Eiillis Keith Hirad Johns Hollingsworth Art A, Hooker, Jr, J . K . Hubbard Q-r .Joseph C . Jackson Donald Johnson Robert Kelly Charles B . Kenahan William King Joseph Koach William Krebs , Ph.D. William Krucke T . J. Kiezkowski Don Lassiter Edmund J . L&ubusch David Lavalette R. F. Lee David LeSourd A. C. Liggett R. H. Locke Sue Loomis William T. Lucas Environmental Protection Agency University of Pittsburgh Asbestos Textile Institute GAF Corp. National Gypsum Co. Abex Corp, QAMA Nicolet, Inc. "Occupations 1 Health & Safety Letter1 Frank C. Frantz & Co. Nicolet, Inc. Dept, of Environment (Canada} Phillips Petroleum Vermont .Asbestos Group Johns-Manvi.lle Corp. Haveg Industries, Inc. Ravbestos-Manhattan, Inc. A-Best Products Co. Plastics Engineering Co. Vermont Asbestos Groxip R. T. Vanderbilt Co., Inc. Diamond Shamrock U. S. Gypsum Kesinoid Engineering Corp. Franklin-Fibre Lamitex Corp. C. Itoh & Co. Dresser Industries - Magcobar Div. Flintkote Company Manning Paper Co. A/C Pipe Producers Assn. Research Triangle Institute TREMCO ino. Bureau of Mines Armstrong Cork Corp. National Insulation Contractors Assn. General Motors Corp. Ravbestos-Manhattan, Ino. Cutler-Hammer Stanford Research Institute Chlorine Institute General Dynamics Corp. Rogers Corp. Research Triangle Institute Maremont Corp. W. R. Grace Co. Automotive Parts Rebuilders Assn. The Breiner Co. A -2 Robert Magdalain Donald Magi11 C. B . Mallory John Marsh Boni Martinez William McCamant Charles A. McClure John P. McGinley p ,P, McGrath Robert H. Mereness Richard Michon Patrician Milligan C. Jerry Morgan Kentaro Mori Fraser Morton R ay m on d L. II. Murphy, John Myers J r ., M.-D. Richard O'Brecht James J. O'Dowd B. J. Pigg Harold F ,, 'X. Plate Dimitry Poutiatine Jack Rainey Herman Ram.ig James J. Reis Harrison B. Rhodes, Ph.D. John Riopelle Lewis S. Ripps Richard H. Rosenburg C. John Rozas John Schmitt Martin Sendecki John J . Sheehan Shin Shima John S , Shockley, Jr. William E, Shoemaker Robert P. Soule Harold D. Stanley John Stender Christopher B. Sullivan June Thompson William C. Thurber Don Tijunelis Joan C. Todd Russell Todd Milt Trospsr Richard Turney Nilfisk of America, Inc. Hollingsworth & Vose Abex CorpRaybestos-Manhafctan, Inc. Textile Fiber Dept. - Dupont Co. Automotive Service Industry Assn. OSHA Certain-teed Corp. FDA AIA/NA Staff QAMA Bureau of National Affairs North American Asbestos Corp. Nippon Asbestos Ltd. Congoleum Industries The Faulkner Hospital Union Carbide Corp. Chamber of Commerce of the U.S. Jim Walter Research Corp. AIA/NA Staff United Asbestos, Inc. Johns-Manvilie Corp. Amatex Corp. Raybestos-Manhattan, Inc, Johns-Manville Corp. Union Carbide Corp. The Bendix Corp. Palmer Asphalt Co. Borg-Warner Corp. Rockwell International Flintkote Company Congoleum Industries United Steelworkers of America Nippon Asbestos Ltd. Bethlehem Steel Corp. NIOSH Clayton Environmental Consultants Pfizer, Inc. Environmental Protection Agency International Fiber, Inc. CPSC Union Carbode Corp. Borg-Warner Corp. "Engineering & Mining Journal" Atlas Asbestos Co. Johns-Manville Corp. Automotive Service Industry Assn. A-3 Ron Vanderveer Jane E. Van Ness R. C. Wareham Isaac H. Weaver Raymond A. Weiskopf Hans Weill, M.D, J. I*'. Welch C. Fred Workman Grover Wremi Milton Wright Rostone Corporation General. Motors Corp. Special Materials , Inc. Raybestos-Manhattan, Inc. Wagner Electric Corp. Tulane University Medical School, Medical Advisor- AIA/NA A/C Pipe Producers Assn. Nicolet, Inc. OS HA Research Triangle Institute A -4 Remarks of Philip E, Enterline, Ph.D. Professor of Biostatistics,- Graduate School of Public Health University of Pittsburgh at Asbestos Information Association Third Annual Industry-Government Conference September 8-9, 1976 Dr. Enter line is Professor of Biostatistics, Graduate School of Public Health, University of Pittsburgh. He received his under graduate education at Westminster College, and his postgraduate degrees at the American University. Dr. Enterline is a recognized expert in the fields of biostatistics and industrial epidemiology. He has published a number of dis tinguished papers. Prior to joining the tfniveristy of Pittsburgh faculty, Dr. Enterline served in a variety of responsible positions in the U.S. Public Health Service. Me has a broad background of experience on health advisory committees and has done extensive consulting work for government, academia and private industry. 176 liste n in g to A lex C r o s s rem inded mo of a grand tour I did of England b ack in 1962 when I first got in the " a s b e s t o s b u s i n e s s ,'1 I'll n ev er forget a young statistician , who w as a s s ig n e d to orien t a g ro u p of us about the p r o b le m in England and what w as going on, and throughout his en tire p resen tatio n he talked a b o u t the " a s b e s t o s i s " f a c t o r i e s in E n g la n d , T h e m a n n e x t to m e sa id ,. l!Oh, how I w i s h we c o u l d g e t h i m to s t o p s a y i n g t h a t : l: I w as ask ed today to talk about a p ro je ct I've been doing fo r the A s b e s t o s Inform ation A sso c iatio n , and I'll spend a little bit of tim e talking about it, not m u c h t i m e , b e c a u s e I h a v e n ' t g o t t e n in t o it, v e r y d e e p l y . T h i s i s s o m e t h i n g Guy Gab r ie ls on a sk e d me if I would undertake and is being done with the help of one of m y grad u ate students. The question w e're trying to a n sw e r is, 'Y'hat did we know about the a sso c ia tio n between a s b e s t o s and c a n c e r at v ario u s points in tim e a s we go back through h isto ry ? What did the ex p erts think about the a sso c ia tio n in 1935, 1940, 1945, etc, ? At any point in tim e what w as the e x p ert opinion? What did w rite rs think about what they w ere seein g? " T h is is an in te re stin g kind of p r o je c t b e c a u s e it r e q u ir e s doing so m e th in g th a t to m y k n o w le d g e h a s n e v e r b e e n d o n e . It m e a n s r e a d i n g not o n ly the s u m m a r i e s of the variou s a r t ic le s , but the introductions and the d is c u s s io n s , and if it's a p a p e r given at a m e e tin g , the d i s c u s s i o n s of the p a p e r fr o m the flo o r and the qu estion s and a n sw e rs, if th ey 're published. A lso, a ll the e d ito r ia ls that have b een written about a s b e s t o s and c a n c e r , te x tb o o k s, le t t e r s to the e d ito r, and questio n s and a n sw e rs in the leadin g m e d ic al jo u rn a ls. Th en try to fo r m so m e k i n d o f o p i n i o n a b o u t w h a t w a s b e l i e v e d at. t h e s e v a r i o u s p o i n t s in t i m e . 177 The g a m e plan i s that -we'll have one o r two g ra d u a te stu d en ts do the ac tu al screen in g of the lite ra tu re (photographing the p ages that a r e relevant) and then have a biostatistician and an epidem iologist independently review this m a te ria l and m ake so m e dec isio n s about what points in tim e w ere ce rtain things known. I want to em p h asize that w e're not trying to find out when should we h a v e known; w e ' r e t r y i n g to find out when' did we know . When did the w r i t e r s o f the variou s p erio d s realiz e what they were dealing with? T h at's so m eth in g a little different than an ordinary literatu re review . T o g i v e y o u a s a m p l i n g o f wh-at w e fin d w h e n w e do t h i s , I ' l l s h o w yo u a couple of things w e've ab stra c te d which illu stra te a n u m b er of points about this particular project. The first slide is a w riting fro m the bulletin of the A m e r ic a n So ciety fo r the C ontrol of C a n c e r and w as w ritten in 1943. I'm going to talk only about a s b e s t o s and lung c a n c e r in o rd e r to n arrow this thing down som ew hat. S l i d e til 1943 Bull. Am . Soc. Cont. of C ancer " A s b e s t o s is c a n c e r of the lung is the m o st recent, n ew co m e r am ong the occupational ca n c e rs of this organ. F ir st d escrib ed in 1935, there a r e now 18 c a s e s of this in d u strial c a n c e r on record observed am ong a sb e sto s w orkers in England, G erm any, and the United S ta te s. The latte r contributed five c a s e s . In asm u ch a s the a sb esto s industry is m ost extensively developed in this country a s b e s t o s is c a n c e r of the lung h a s fo r us a sp e c ia l hygienic and sociologic significance. Now this is interesting b ecau se it's based upon rep orts on an a s s o c i ation of a s h e s t o s i s and bronchogenic c a rcin o m a at au topsy, and it is w ritten b y B il l H e u p e r w hom s o m e of you s u r e l y know. He -wrote a g r e a t d e a l about o ccu pation al c a n c e r. Now let m e show you a w riting in 1961. T h is slid e is from the Jou rn al of the A m erican M edical A sso ciatio n . T h at's a very p r e s tigious journal, and this writing is even m ore p restigiou s because this happens - 178 - i:o c o m e f r o m a s e c t i o n o f t h a t j o u r n a l th at a n s w e r s q u e s t i o n s t h a t a r c a s k e d by the m e d ical p ro fessio n * If yo u 're a p racticin g physician and want the late st inform ation on a p a rtic u la r topic, you write to the Jo u rn a l. Th ey r e fe r y o u r letter to som eone they c o n sid e r a leading expert and that p erso n will then rep ly in the colum ns of the jou rn al to your question. Slide Z " T h e re is no epidesniological evidence, that s il ic o s i s , resultin g fro m undue ex p o su re to free silic a , p rodu ces c a n c e r of the lung. Of the s e v e r a l s ilic a t e s , a sb e st o s is held in su sp icio n , e sp e c ia lly in G r e a t B r ita in . In the A m e r ic a n li te r a t u r e th e re is no evid en ce that there is a relationship between a sb e sto s is and lung can cer. The reaso n for the differen ce between the E n glish and A m erica n e x p e r i e n c e is not a p p a r e n t . It m a y be due to a d i f f e r e n c e in the type of a sb e st o s fib e r o r to the total d o sag e. " A s you m ight ex p e c t, in 1961 th ere w as c o n sid e r a b le c o r r e s p o n d e n c e which followed th is, h o w e v e r, the w r ite r stu c k to h is opinion and defended it on the grounds that there w as no epidem iologic evidence and points out in su b se q u e n t c o m m e n t a r y in the J o u r n a l that without e p id e m io lo g ic e v id e n c e no p i c t u r e o f a. d i s e a s e w o u ld r e a l l y be c o m p l e t e . T h i s i s i n t e r e s t i n g b e c a u s e what is happening in 1961 is applying a different set of ru les to decide if th ere is an a s s o c i a t i o n a s c o m p a r e d to 1943, In o th e r w o r d s, the ru le s w e r e ch an gin g at the sa m e tim e know ledge w as developing. T h is type of com m entary is not indexed and calls fo r reading lots of jou rn als, many of them w eeklies. My student has read all issu es of the Lancet (which is probably the leadin g m e d ic a l jo u rn al in the w orld), the B r itish M ed ical Jo u rn a l, and the Jo u rn a l of the A m e ric a n M edical A ssociation, back to 1935 and h as picked out a lot of m a te ria l that 1 can't p resen t here today. So f a r w e've gotten up throu gh 1961. A fte r that it r e a lly g e ts tough b e c a u s e the 179 volum e of literatu re explorer] a fte r that date, p a rtic u la rly a fte r the 1964 con ference in New Y ork, I'm sim p ly giving you so m e idea of the type of p ro je ct that Guy has launched us upon, what this p ro je ct in v o lv es, and w here we are at p resen t. Incidentally, w e've located som e v ery h u m orou s stuff. F o r e x a m p le , in 3949 O v a ltm e w a s being a d v e r t is e d to p re v e n t p n o u m o n o c io s is and s s b e sto sis. So we've com e a long way since 1949* .Let m e now p r o c e e d to s o m e th i n g q u ite d i f f e r e n t - - and t h i s is stim u lated by an article I saw in this m o rn in g 's p ap er, it's the m a tte r of how m uch d i s e a s e will be produced fro m ex p o su re to a s b e s t o s . We've been w orking on a m odel to predict how much d ise a se is produced with co n tinuous ex p o su re at any given fib er lev el o v e r any given p eriod of tim e. F o r e x a m p l e , we could think o f w o r k e r s who s t a r t at a g e 20 and who w o r k f o r 50 y e a r s at 2 fib e rs p e r cc . How m uch d i s e a s e would we expect to o cc u r? T h is is re a lly the im portant question, I think. What w ill happen to people if we take ce rtain action s on th eir beh alf at this point in tim e? F ir s t , to review rapidly so m e elem en ts of c a r c in o g e n e sis needed to develop a m odel, we know that if yo u 're exposed to a carcin o gin , you won't get can cer tom orrow , but that there will be a peak incidence at som e future date and th e re a fte r it ta p e rs off. T h is distribu tion se e m s to follow a m a th e m atic al function called a log norm al. Another im portant notion for m odeling the effects of a sb e sto s exposure i s that fo r low d o se r a t e s the tim e it tak e s fo r c a n c e r to a p p e a r w ill be very long. On the other hand, if you have a very high d o se rate , c a n c e r will a p p e a r rath er quickly. I'm thinking now about groups of people, say 100, 000 people e x p o se d at differen t le v e l s . In oth er w o rd s, th e r e i s a re la tio n sh ip between 180 the intensity of e x p o su re and the latent period. Th us, a population would have to live a long tim e to ex p erie n c e a full resp o n se to e x p o su re s at very low lev els. Now if we add to this the assu m p tio n that this d o se - r e sp o n s e relatio n sh ip is lin ear, we can develop the fam ily of re sp o n se c u r v e s. The linear d o se -re sp o n se idea m eans sim ply that every increm ent of dose ca u se s a like in crem en t in re sp o n se - - a straigh t-H n e relation sh ip. That h as so m e ac cep ta n ce a s fa r a s c a n c e r is con cern ed. It's one that you m ay not like, how ev er, b e c a u s e it m e a n s that any little bit of a s b e s t o s w ill p ro du ce s o m e kind of resp o n se given enough people and enough tim e. If you talk about a threshhold lim it, the id ea is that a little bit won't produce anything that you have to have a ce rtain am ount - 2 fib e r s, 5 fib e r s, e t c ., b efo re you produce any d i s e a s e . I don't think it really w orks that way. I think that any little bit does produ ce som eth in g. H ere is the output of the m odel, and is kind of the end product. Slide #3 Cumulative Relative Risks for R espiratory C ancer at Seven Levels of Continuous Exposure Exposure Level ..if/c?) 1/2 1 z 4 8 16 32 20 Y ear 1 000 1. 000 1.000 1. 005 I. 050 1. 390 3. 291 40 Y ear 1. 000 1.003 1.026 1.154 1.684 3. 400 7. 861 60 Y e a r 1.003 1,021 1.098 1.361 2, 075 3. 702 7. 032 - 131 Unfortunately, in the in te re st of tim e, I !ve had to skip so m e in term ed iate steps and assu m p tio n s but could provide these to anyone in terested . T h is say s that w hore the cum ulative re la tiv e r is k is c a r r i e d to t h re e d e c im a l p l a c e s , no effect of a sb e st o s on the death rate fro m lung c a n c e r can be detected until 60 y e a r s of ex p o su re at 1/2 fiber, 40 y e a r s at 2 fib e r s, and 20 y e a r s at 4 fib e r s. One r e a so n fo r this is the a s s u m e d long latent period fo r low d o t e s . A f t e r 60 y e a r s , for ex am p le, in c re a se d lung c a n c e r would ap p ea r; but, of c o u r se , for p e rso n s entering the la b o r force in their 2 0 's, other c a u se s of death a r e p retty im portant at this point. Now that we know what the r is k is at vario u s ex p o su re le v e ls, we could calcu late absolu te n u m ber of c a n c e r s if we knew how m any people w ere ex posed . I went back to som ething the A s b e s t o s Inform ation A sso c iatio n did som e tim e ago and m ade a slid e of it. H e re a r e quotes fr o m Irving S elik o ff about how m an y people a r e e x po sed and how m an y will die from, a s b e s t o s - related diseases. Slide #4 D r, I. J . Selik off . . . . P red ictio n s No. of W orkers D escription of Cohort Total Deaths from A sb estosis Lung Cancer k. M e s o t h e l i o m a A rticle in W all S treet Journal -- 6/8/72 "Studies by D r. Irving Selikoff . . , Lead Him To Predict. . . " 25 0, 000 All w orkers currently E m ploy ed in the A sbestos Industry 85,000* A rticle in the New York Tim es. , .6/13/72 (Five Days Later) "If our experien ces.. . , A r e a G u i d e . . . . 11 500, 000 All w orkers currently and previously employed in the A s b e s t o s Industry 170,000 Testim on y at Toxic I , 000, 000 Substances Hearing - "Oti r stu d ies in dicate. . " All w orkers currently, &sr e v i o u s l y , a n d urfiD-isdlL. erd,eeurmsstpr yl o yine dt'hi'ins the A sb esto s country 340,000 ^ A c t u a l Q u o t e d P r e d i c t i o n w a s 9 5 , 0 0 0 ^ B u t t h i s i n c l u d e d d e a t h s f r o m GX G a n c e : (- 182- ) T h is is esse n tia lly the m a te ria l that w as quoted in this m o rn in g 's p ap e r and ap paren tly a s s u m e s that a ll p e r so n s exposed have been and will be exposed like m e n in h i s s t u d i e s - - m o s t l y a s b e s t o s i n s u l a t o r s . We h o p e that, i s n ' t s o . What we'd r e a lly like to know is how m a n y men would be affe cted by a s b e s t o s if e x p o su re s w ere at 4 fib e r s, 2 fib e r s, e t c ., sin ce that is what the g o v e rn ment is deciding. L e t 's ju st take one n u m ber. L ee's take the first n u m b er, 2 5 0 ,0 0 0 ~fchat's a ll w o r k e r s c u r r e n t ly em ploy ed in the a s b e s t o s in d u stry . One q u e stio n we might a s k is how m any of th ese people would you expect to die of lung c a n c e r if t h e r e w a s no a s b e s t o s a ro u n d . L e t ' s s a y they n e v e r had been and n e v e r would be exposed to a s b e s t o s . Of c o u rse , som e people would still die of lung c a n c e r b ec au se lung c a n c e r h a s lots of c a u se s -- c ig a re tte s, a i r pollution, etc. A lso , you have to r e m e m b e r that things can happen to you other than dying of lung ca n c e r. You could get hit by a truck or have a h e art attack {so m e people a r e going to have a h eart atta ck when they read so m e of this stuff), I e stim a te that if th ere was no a sb e st o s ex p o su re, in a gro u p of 2 5 0 , ODD m e n t h e r e w o u l d b e 1 2 , 5 0 0 d y i n g o f l u n g c a n c e r . Wow, w h a t i f t h e s e m en w ere exposed continuously to half a fib e r for 60 y e a r s ? F r o m Slide #3, we can e s t im a te that 1 2 ,5 3 7 would die of lung c a n c e r (1 .0 0 3 x 1 2 ,5 0 0 ). If th ese 250, 000 men w ere all exposed continuously to two fib e r s, 12, 762 would die; if exposed to fonr fib e rs, 17,012 would die, and if exposed to eight fib e r s , 25, 937 would d ie 'o f lung c a n c e r. T h is is a fte r 60 y e a r s . Looked at an other way, 250, 000 m en exposed for 60 y e a r s to half a fib e r w ill produce 37 lung ca n ce r deaths, etc. 183 The p ro b lem then co m e s down to th e se e x c e s s deaths and how m an y there are at these different exposure lev els. To sim ply deny that there a re any e x c e s s deaths I don't think is ev er going to get any p lac e, hut 1 think to recognize how m any w e' re talking about m ay have so m e m eaning. Given i m p r o v e m e n t s in. i n d u s t r i a l h y g i e n e , I ' m s u r e w e ' r e not t a l k i n g a b o u t e x c e s s e s of the m agnitude Dr. Selik off p re d ic ts. Of the 100 ,0 0 0 he p red ic ts w ill en ter the industry o r will be exposed during the rem ain der of the century, a 2 fiber standard at 40 y e ars of continuous exposure would in crease deaths from 25,000 to 25,650. Eet m e show you m y last slide which is a check on how w ell m y model actually predicts. S lid e #5 Relative Risk Predicted by Continuous Exposure M odel at 35 f/c c C om p ared with Relative Risk R eported in Study of U .S . Insulation W ork ers O bserved Y ears from Onset P red ic te d Relative Risk of Exposure Relative Risk (Adiusted i 10 1 . 0 0 .0 10-14 1.6 2.2 15-19 2. 8 3. 4 20-24 4. 3 3. 1 25-29 5.4 4. 5 30-34 5. 7 6* 4 35-39 5 .4 5. 4 40-44 4. 8 4, 9 45-49 4 .1 3. 6 50+ 3 .4 3. 8 184 D o e s m y m o d e l p r e d i c t S e l i k o f f ' s f i n d i n g ? T h e s e d a t a a r e f r o m S e l i k o f f 1s study of 17,000 insulation w o rk ers, Selikoff has undoubtedly produced so m e of the m ost m agnificent ep id em io lo gical data I've seen , and I think this 1 7 ,0 0 0 insulation w orkers study is truly a great study. You see there is a very good co rresp o n d en c e. The m odel p re d ic ts pretty m uch what Selik off o b serv ed . Notice, for exam ple, that Selikoff observed le ss and le ss can cer a s tim e went on. T h at's what the m od el p redicted too. Notice that his peak o c c u r r e d fo r m en who w ere e x p o se d 30-34 y e a r s ag o , and l get e x a c t ly the s a m e p e ak . T o s u m m a r i s e , it i s p o s s i b l e b a s e d upon, the e p id e m io lo g i c a l data now available to predict what will happen if various actions are taken at this tim e in regard to a sb e st o s e x p o su re and if v ario u s stan d ard s a r e set. Thip should be he lp fu l in decidin g w here you want to se t this thing,, I think it would be stickin g ou r h e ad s in the sand to sa y that nobody will e v e r be affected at 2 fibers or at any other finite level. - 1.85 - Remarks of Guy G. Gabrielson, Jr. Chairman of the B o a r d r Nieolet Incorporated at Asbestos Information Association Third Annual Industry-Government Conference September 8-9, 1976 > Mr. Gabrielson is Chairman of the Board, Nicolet Incorporated. A Vice President of AIA/NA, he also serves as Chairman of the Association's Asbestos Regulation Task Force. Mr. Gabrielson is a lawyer, businessman, and prominent civic leader. .186 I used to think that the last speaker was fortunate because he could have the benefit of all the wise things that were said by the informed speakers who preceded him, He could assimilate all this information, put it together, and make a profound im pression on the audience. I'm not so sure as I stand here this afternoon that that is the advantage I thought it w a s , The digadvantage of being the final speaker is that all you who have been here through these proceedings have a much better apprecia tion of the complexities of the problems of which we are dealing, and I 'm afraid you might be somewhat impatient with a simplistic kind of speech that I might make if I tried to put together in one piece.all the things that we've heard during the last day and a half, I'm glad I was here during these proceedings, but I have my regrets also. To perform the function I have undertaken on behalf of AIA/NA and the asbestos industry, I think it is essen tial that I endeavor to preserve my objectivity and that I try to understand the broad perspectives of the problem. Unfortunate ly when I come to a meeting of this kind and I listen to the speakers who are acknowledged experts in their fields, obviously understand their subjects far better than I ever will, I become intrigued with the details and it becomes difficult for me to step back so that I can see the forest and not the trees -- a 18? very, very confusing subject. X thought the other day about a motion picture X saw a long time ago. It must, have been at least 40 years ago when X was just a b o y . I can't remember anything about the plot of the motion picture. I know that I enjoyed it. I remember only one incident in the motion picture. The setting was a steel mill. Two men who worked in the mill during their lunch break or coffee break or whatever it was were arm wrestling, and they put their elbows on an anvi1. At either end of the anvi1 was a short piece of railroad rail that was red hot so that as the two men strug gled you knew that the loser's hand was going to be forced down on the hot piece of railroad rail. Well that was a minor inci dent in the picutre. It happens to be all that I can remember. But I do remember that the general tone of the picture was that steelvjorkers are tough guys. Steelworkers are guys who know the risks they are taking, and they are willing to d.o that job de spite the risks. It proved their virility. There was no sug gestion in the motion picture that the management of the steel company might have been at fault for not taking adequate safetyprecautions in the steel mill. These men were surrounded by hazards of all kinds. Most of them I recall would have been fatal hazards, but to my romantic mind at that age I thought that was perfectly all right. These were men who knew the risks of working in a steel mill. They assumed those risks. Presum ably they received premium pay for doing it. And, most impor tantly to that young boy, it gave an opportunity to prove what 188 he-men they were. Probably the atmosphere that was created in that motion picture reflected the history of our attitude toward safety in industry. Even at the time I saw it, it may have been somewhat of an anachronism. I suppose Jack Sheehan would say that the philosophy of management which was reflected in that motion picture could be described as the marketplace type of solution to the problem of industrial health and safety. In other words, at one time if not when I saw that motion picture, at least some time before that, I believe we generally accepted the thesis that, if we didn't deceive our employees, if we were candid in acknowledging what the hazards of the workplace were, and they chose to accept those hazards, perhaps demanding some premium pay for it, that was fair and equitable and a moral solution to the problem. Well, today we don't look at things in the .same way. Today we say and our statutes explicitly say that our employers have an obligation to provide each employee with a safe and healthful working environment. That might be disappointing to the ro mantic boy who saw that movie years ago, but I think most of us today accept that thesis. Times have changed and we don't rely on that old market mechanism that Jack Sheehan no longer will trust. We share with him the distrust of that market mechanism. Today we handle the occupational safety and health problem in two w a y s . We impose upon employers a statutory obligation 189 to provide a safe and healthful, workplace, and we issue rules and regulations to make sure that he docs in fact provide that kind of workplace. Recognizing that we will not always be successful in protecting our employees from accident or damage to their health, we have a workman's compensation program which provides monetary compensation to the employee if our safety precautions fail. This is the approach which v;e have: adopted. I think it is overwhelmingly supported in this country. I think most of us, if we were required, to say what we would favor, would probably say, "Well, we favor that too." But we're not happy with it. Much of what has been said during the last day and a half clearly evidences the fact that we are unhappy about this kind of treatment of the problem. For instance, in the development of rules -- occupational safety and health standards to protect our employees -- we heard Grover Wrenn say that we must allow, as I understood him, approximately one year to develop, a stan dard. The most that OSKA seems to be able to undertake at one time, at least in my o b s e r v a t i o n i s the development of about five standards. Well, assuming that they can develop five standards per year, taking a year to develop each one, and accepting a number which 1 have seen published somewhere that there are perhaps one thousand suspected carcinogens used in industry, we can expect that we will have standards covering our presently known suspected carcinogens in about 200 years. This kind of procedure is cumbersome, and it is of concern 190 to me, and I know it is of concern to you. It is of concern to industrialists as well as to labor leaders. But I ask myself what is the alternative? Shall we rely upon the good will of employers to provide a safe working place? Well, Jack Sheehan wouldn't do that. And when he said as much I winced because in part I have to agree with him. Yes, good will on the part of employers will take us a certain distance, but I have to say candidly that if the provision of health and safety for my em ployees is going to be a very expensive undertaking, if a par ticular step is going to be very costly, and if I have some doubts about its efficacy in any event, I 'm going to be very reluctant to spend that money because I 'm afraid that my competitor won't do it and he *11 have a competitive advantage against m e . Good will will take us a fair distance, I think, despite Jack Sheehan's sentiments in this regard. But I don't think it will take us all the way. I think, candidly, we need some kind of prod in order to make us provide a truly safe workplace. From where can such a prod come? Our customers arsn1t going to boycott, us if we don't provide a safe workplace in the production of our products. If they would it would be a very effective motivating factor. But consumers generally aren't that sophisticated, and their buying choices are much more selfcentered and not nearly that visionary or idealistic. That leaves us with the procedure which we're following now which I find very cumbersome and inefficient. The only alternative I've been able to think of would be perhaps to remove the limitations 191 - which are contained in our workman's compensation statutes, remove the limitations upon the employee1s right to sue his employer for damages. That if it were done X suspect would provide a very considerable motivation to employers. But if our statutory regulatory system is inefficient and cumbersome, imagine how inefficient and cumbersome the other alternative would be -- all these individual questions involving- individual employees to be resolved in our courts of law. The 200 years would be a modest period of time it seems to me compared to the time period that would be necessary to clear our courts of all these thousands of cases, particularly when Congress shows no particular disposition to appropriate the money to expand our court system. For better or for worse, gentlemen, unless you can siiggest a better answer for our country, I think we are .stuck, with the approach which we are trying to use now and we have no choice but to try to make that approach work as best we can. It is to that task that the Asbestos Information Association is dedicated It is to this effort that I currently am devoting a considerable amount of my time. In the course of my activities with the AIA/HA I, of course have frequent contact with scientists who are working in this field. I talk to and work with Hans Weill, Phil Enterline, Paul Kotin, George Wright, men whose skills and experience I respect to the highest degree, men who know far more about all these asbestos-health related subjects than I could ever hope to learn. But I can't avoid the temptation to attempt to be an expert myself. One can't think about these things extensive ly without trying to organize it in one's own mind and to one's own. satisfaction. X listened yesterday to Hans Weill talk, and X tried to summarize quickly in my own mind what he was saying about asbestos and disease. I want you to listen to what X s a y , remembering that this is a Gabrielson version of Weill, and he is not responsible for what X am saying in attempting to sum marize his opinion. tie seemed to me yesterday to say -- you can. check this against your own recollection -- he seemed to express the notion that all asbestos diseases are dose response related, in his opinion. He appeared to me to say that he was satisfied that there is a threshhold for fibrosis, that is asbestosis, and for bronchigenic cancer, lung cancer. He seemed to me to imply, and I believe from my previous conversations with him that this would be a fair statement, that our present standard of two fibers is appropriate for that threshhold level. He expressed some doubt, I thought, as to whether or not there is a thresh hold level for mesothelioma. I 'll stop right there talking about Hans's opinion and turn to Grover Wrenn's opinion. Grover Wrenn appeared to me to say that there is a dose response relationship, but there is no threshhold level. X listened to Phil Enterline this afternoon, and I rather liked what he said -- and perhaps It will help me to reconcile what the other gentlemen have said. I thought from listening to 193 Phil that he said yes, there is a dose response relationship, hut there is no threshhold. However, a dose response relation ship involves not only the seriousness of the disease but its latency period. So you may get. to sero risk within a lifetime or you may get to aero risk beyond a lifetime. I wonder if that enables me to reconcile the view of Hans Weill and Phil Enter line , Perhaps they see the thing in the same way though they don't express it in the same way. Perhaps Hans Weill would be willing to say yes, there is no threshhold, but for fibrosis and bronchigenic cancer the effects at low fiber concentration go beyond the normal human lifespan so that you finally get to the sero risk way out in the term of human experience. Grover Wrenn seems to say that there is no threshhold; you get to aero risk at aero exposure, and in the case of all diseases that will occur during a working lifetime. What do you do then in trying to set a regulation if you follow Grover Wrenn's hypothesis? What he seemed to say this morning was that the only way we can be sure that there is no risk of disease is to ban asbestos, but we c a n 't do that. We can't go to 2 ero risk. Therefore, we will make our decision based upon grounds of feasibility. Well, that may be an easy thing to say, but it's a very difficult thing to implement. W h a t , after a l l , is feasible and what is not feasible? The position that AXA/NA has taken in responding to the OSHA proposal I think can be summarized in this way. We do believe that there is a dose response relation 194 ship between asbestos and all the diseases which it causes. We do believe that the present two-fiber level is sufficient to protect our work force during a working lifetime. We admit that we cannot prove that, particularly in the case of mesothelioma. We take the position that Hans Weill has taken, that until it can be established that this is not a safe level we should not pay the cost of severely damaging or destroying a valuable in dustry. That is the position we took in the case of the manu facturing regulation. L e t 's stay with the two-fiber .level until it can be demonstrated that that is not adequate to protect the safety of the work force. Can we do this in good conscience? Well, I wouldn't be arguing this case if I di d n 't believe that we could. And 1 must confess that in addition to the information which I tried to gather from the medical and. scientific community I rely to' a great extent upon my personal experience in the asbestos indus try . I would concur, strongly I think, with the kind of statements that were made by Alex Cross and that is that the present incidence of disease which we are observing is the prod uct of very high exposure to airborne asbestos. I am not per suaded by the assumptions made in some scientific papers that certain types of domestic exposures, neighborhood exposures, necessarily were either low or discontinuous, intermittent. I believe from what X have seen during my lifetime's work in the asbestos industry, and X believe from my own conversations with veterans in this industry, that exposures were extremely high - 195 in the p a s t , extremely high even in the neighborhood c a s e , and I believe often in the domestic case. To place this thing in perspective for myself, I believe that today's two-fiber standard, if achieved, will be many, many times lower than the exposures which have created the disease which we are observing today. In good conscience, I can and I do support the two-fiber standard, and I will argue for that standard. I have recommended to the Executive Committee of the AIA/HA that we use every tool in our command to make our point with the regulatory authorities, that we-exhaust our administrative remedies, and if at that point we still do not have the kind of standard we think we require to run our b u s i - nesses that we go ahead and go to court to challenge an unsatis factory regulation, I believe the system permits us to do this and we can. do that with a clear conscience. It's interesting to thi n k , however, despite Jack Sheehan's rejection of the marketplace as the final arbiter of occupational safety and health, that in the final analysis it will be in the marketplace which decides. The market can make its decisions known either through purchases by buyers in the marketplace or sometimes through the political process. If we look at occupational safety and health in gross and think again of those one thousand suspected carcinogens plus all the other potentially toxic materials that are used in industry and if we recognize that there are people who are 196 arguing for zero exposure or a practical ban on many Oi: these substances, we begin to get an idea of the enormous economic cost that might flow from the successful pursuit of an objective of that kind. Those who look upon the consumption side of our economy as the measure of our standard of living would say that to go the distance that some of the zealots seem to be advocat ing would lower our standard of living. Well, .stated in those terms I would say that's true. An alternative, however, would be, and perhaps more fairly would be, to say that occupational safety and health is part of the standard of living. So we would be trading cheap goods for more occupational safety. We would be trading plentiful goods for more occupational safety depending upon how far we go in this direction. X think it is safe to say that there will be a limit to which the American people will be pushed. There will be a limit to the quantity if you wish to call it that, to the quantum of occupational safety and health which they are willing to buy. When their automobile begins to cost 4, 5, 6, 10 times as much as' it did, when they find that they c a n 't buy a house because it's beyond their means, when they find that they have to work longer hours or have shorter vacations because we are devoting more of the resources of this economy to the pursuit of diminish ing returns in the occupational safety area, they will finally blow the whistle. And, they will do it not so much through the marketplace as through the political process. Believe you me, 197 ladies and gentlemen, their congressmen will respond. 'We have the simple example of the seatbelt interlock. It didn't last very long when the motorists became impatient,with it. So too will be the case with all occupational safety and health regula tions. In the final analysis it will be the public, the consum ing, voting public who will decide how much occupational safety and health we are to have. Let us hope when that time comes we don't get a pendulum effect and they throw the whole thing out in disgust. That conceivably could happen. I'm afraid Jack Sheehan is disappointed really or will be disappointed. The final determination will be a marketplace determination. It will be expressed, I believe, through our elective process rather than through buying and selling in our stores. But finally it will be the people who decide how much occupational safety and health we should have. And that is going to be the kind of cost benefit analysis which is anathema to so many labor leaders and others who are sealously advocating more safety and health. We are, after all, all of us, businessmen, labor leaders, legislators, administrators, we are all trying to guess at what the decision of the average man will be -- how much occupational safety and health does he want to buy? So that forces us back to a cost benefit analysis. Increasing expenditures of money and increasing efforts directed toward occupational safety and health cost more and more and more money and give us diminishing returns. If, in fact, we do have a straight line relationship 198 between exposure and onset of disease and/or its severity, then we must look at this relationship as best we can even in the absence of hard data. This is the kind of subject that a law school student would very much enjoy. Let me postulate a case. Let me say that the membrane filter test method is very accurate and very reproducible down to several decimal points, and let me say that in our asbestos industry we can reduce average exposures in our workplaces by 1/100 of a fiber by the expenditure of a hundred million dollars, which we then are going to charge to our customers. And that this reduction of .1/100 of a fiber per cc in all our workplaces will benefit one very sensitive man who happens to be working in one of our factories, and as a result of this reduction this man lives to be 76 years and one week instead of dying on his 76th birthday. After a l l , this is what w e 're talking about when we're talking about mortality. We haven't yet discovered how to live forever, so all we're talking about is how soon are wa going to die. Well, this fellow is going to live one week longer because we paid a hundred million dollars to make an improvement. Obviously my example is absurd, but it makes the point that we cannot conscientiously duck the question of cost benefit analysis. Despite the fact that we may be branded as crass privateers for our interest in the economic aspects of this subject, w e , gentlemen, have no choice but to look at it in these terms and to call these matters to the attention of the 199 regulatory authorities so that they give it attention t oo. They must respect these considerations if they are concerned about the reaction of the general public and ultimately they must be so concerned. We, I think, have the obligation to do this job and to do it as responsibly as we can. Although there are many respects in which our effort in the manufacturing case were deficinet in my opinion, I think on the whole we did a good job with the time that was allowed to us, and I think we did a responsible job. And I think that that is recognized at OSHA and elsewhere. We now face the prospects of a regulation of asbestos exposures in construction, and we pro pose to address ourselves to that problem in the same responsible way. We will make an effort in this case even to improve the quality of our response, but we can't afford to ignore it because the construction market represents such a substantial portion of our total market. This is of vital importance to the asbestos manufacturing industry and must be so treated. Although we have much work to do on this problem between now and perhaps next spring, it is the present feeling of those who are most actively engaged in it that we will, for a variety of reasons, undoubtedly advocate the retention of a two-fiber per cc exposure level in the construction industry. We have in my opinion, however, a more difficult problem to address in the case of the construction regulation, and that involves all the other parts of the regulation. I believe, speaking selfish ly as a manufacturer of asbestos products, that the potential 200 harm to our manufacturing industry is greater as a consequence of the promulgation of a construction regulation than it is as a consequence of the promulgation of a manufacturing regulation. For this simple reason, if the burdens of medical surveillance and monitoring and record keeping are too great and those bur dens are imposed upon our contractors, the contractor can s a y , "I'm not going to be bothered with this hassle. I'm just not going to put up with this kind of problem and this expense and this inconvenience even though some may argue that-it isn't terribly expensive." He's going to look for substitute materials, and to him it really doesn't make a great deal of difference because buildings will be built; factories will be constructed; highways will be laid; bridges will be built whether asbestos is used or not, and his business won't be destroyed. He doesn't have the same vital interest that we do in this construction regulation. The most difficult, part of our task in this case will be to try to mitigate the impact of these other elements of the regulation, the medical surveillance, the monitoring, the record keeping, so that our contractor customers will not be discouraged and will not accelerate their search for other materials so that our market will be preserved. Wow we can point out to the authorities, the damage that may be caused to our industry by a regulation that is too strict in these areas, but we must go beyond that, in my opinion. We must find a rationale that will support on occupational safety and health grounds the different treatment of these factors from 201 the treatment which will probably be given to them in the manu facturing sector. Can that be done? Well, I think perhaps it can, but it's going to require a great deal of data gathering, a great deal of research, and a great deal of careful thought not only on the part of the members of the industry who are working on the problem but on the part of the contractor who will be assisting us in the technological feasibility and economic impact study, I believe we can take the reasonable position, in the absence of good solid scientific data, that two fibers per cc will adequately protect the workmen in the 'workplace. We have to be honest and acknowledge that we can't prove that. It seems to me that our obligation, then, if we are successful, is to be very sure that we act responsibly as businessmen and that we should not be satisfied with a two-fiber level in any case where that level can be lowered. In other words, even, gentlemen, if we succeed in persuading the government that two fibers is the standard which should be required of us, it is not the standard which we should require of ourselves. We have an obligation to our employees and to our employees and to our own consciences to make every effort that we can to keep fiber levels at the lowest possible point. We have the obligation also to be candid with our employees and acknowledge to them that we d o n 11 really know where a safe level is and therefore they should join with us in the effort to keep the factories in which they work and the job sites where they work as clean and as free of dust 202 as possible. And I can't help but think that this may be one of the most important things which we can do because my own pragmatic observation is that more dust is created by careless ness and poor work practices than is ever created' by defective engineering controls. We, gentlemen, can go a' long way to re duce these exposures simply by doing our jobs right. And here we do encounter some difficulties which takes me back to my movie. We have in the work force today people like that young boy who saw the movie, people who worship machismo, people who say, "I. ain't scared of that fiber," and won't wear their respirator or won't take other precautions. "I want to show you what a he-man I am." We have a big job ahead of us to explain to our employees that this is in their best interests, and if they want to prove how virile they are, perhaps they should go out on the week-ends and do some sport parachuting' I think perhaps I've talked much too long this afternoon, I would like to close by referring to a conversation I had last evening, and someone said to me, "This is our third industrygovernment conference." He said I wondered after the first one if we'd be back again. And he said that here we are back 1for the third time. Well, I admit, gentlemen, that X sometimes become discouraged by the enormity of the problems which face us, but on the whole I try to keep my optimistic attitude. And on the whole I have the feeling that there are enough people in enough important places who will respond to reason and logic so that this whole issue can successfully be resolved. In the spirit of that optimism I'd like to thank you for listening to me, and I'll see you next year! 203 -