Document wq33b3jYoYkQX75YoE110wGBQ

socma SV'.V THEY!*C CPCAYl.C C^EM'CAL 1075 CENTRAL PARK AVENUE. SCARSCAL December 10, 1979 ;V ''' The Honorable Eula Bingham Assistant Secretary of Labor U.S. Occupational Safety and Health Administration 200 Constitution Avenue, N.W. Washington, D.C. 20210 j;!'. The Honorable Douglas M. Costle Administrator U . S--^Envi ronmental P rot ection Ag ency 401 M Street, S.W, Washington, D.C. 20460 Re: Labeling Rulemaking Dear Dr. Bingham and Mr. Costle: The Synthetic Organic Chemical Manufacturers Association, Inc. ("SOCMA"), a non-profit trade association whose membership includes more than 100 large and small manufacturers of synthetic organic chemicals, understands that your agencies intend to publish within the next few weeks an extremely broad proposed labeling regulation. The point which SOCMA here seeks to address is that EPA and OSHA should publish an advance not ice of proposed rulemaking ("AN?R") before publishing a propos ed regulation, because of the complexity of the issues, the substant ial legal questions, and the severe economic effects created by an omnibus labeling rule. Substantial Legal Questions The legal problem is that there are serious questions as to whether EPA or OSHA has statutory authority to promulgate an omnibus labeling rule. This has recently be^n brought to your attention, and it would be redundant for SOCMA to reiterate or expand upon those submissions. (See letter to Mr. Costle from counsel to Chemical Manufacturers Association, dated October 26, 1979; see also "Memorandum of Points and Authorities in Support of Chemical Manufacturers Association for Leave to Intervene: as Defendant", dated October 17, 1979, filed in Public Citizen 1 Health Research Group v. Marshall, Civil No. 79-2581 (D.D.C.).) S4L 022484 Dr. Bir.9r.am and Mr. Costle Decemcer 10 19 7 9 W1 d e s p r e ad Z c o n o rr> 1 z Impact We have noted recent statements in OSHA's regulatory agenda that: 1) OSHA expects to publish a proposed labeling rule by January I960, and 2) the rule is expected to be of such wide spread impact that a regulatory analysis will be prepared. (44 Fed. Reg . 65556 , 5557 2 (Nov. 13 , 19 79); see also 44 fed. Reg. 6827? (Nov. 28, 1979).) We also understand that there exists an economic report concerning an earlier draft of a broad labeling standard. We understand that this report (bv Foster 0. Snell) , and a peer review of that report (by Southwest Econometrics), demonstrated that the earlier labeling proposal if implemented would have im posed costs upon the rJ . S . economy in terms of billions of dollars. These studies, the labeling proposal upon which they were based, and subsequent draft labeling proposals received at most only limited outside review. (We understand that a request to obtain these and other documents under the Freedom of Information Act was filed with your agencies in November.) The widespread impact of your contemplated labeling regulation, and the confidential handling of the earlier labeling proposal and its economic analyses, further underscore the need to publish an ANPR. Criteria for Determining Carcinogenicity We further understand that a labeling rule that is being considered by E?A may include a list of substances that are believed to be care inogenic or otherwise hazardous, and as to which labeling is believed to be appropriate. It is imperative, in advance of any such listing, to publish an ANPR seeking information as to what cri teria should be used in selecting the substances to be listed. An ANPR also is necessary to consider the relationship of the labeling rulemaking to, for example, OSHA's controversial proposal for generic regulation of alleged carcinogens in the workplace, and EPA's equally controversial proposal to regulate alleged airborne carcinogens. Moreover, failure to publish an ANPR will create a substantial- like lihood that non-carcinogenic products will be listed as carcinogens, with a substantial adverse impact upon the market for these products. The Need for fJo-to-Date Information We recognize that EPA and OSHA have already obtained some information from the public concerning labeling. Most of information is not currant because it was obtained in response request for information that OSHA published almost three years (42 Fed. Reg. 5372 (Jan. 23, 1977).) OSHA's recent statements this to a ago. SAL 000022485 3 -- . Bin cham mb Mir. Cos 3 13 7 9 describing oh2 widesoread scope of the presently ccroenplaned rulemaking, end *he inevitable chances in labeling r;>o'jiremenrs over a three-vear period (inducing, for example, major new statutes such as the Trade Agreements Act of 1979, discussed below), further emphasize the need for your agencies to publish in ANPR. ;SHA its*<=e>1l * nr- ew recognizes the necessity to update ANPRs. This is iiiustrat ed by OSKA's handling o;: ANPRs in its rulemaking concerning ant ry into and working in Confined spaces, where OSHA stated: "In cc r.sideration of both the complexity of the issues and the period of time since the previous Advance Notice, OSHA has decided to again request information of value to the devel- ooment of its proposal on confined spaces in general industry." (44 Fed. Reg. 60334. ) _1/ It is essential to follow the same course of action with respect to the complex issues of Labeling rulemaking, including circulation of a draft ANPR for comment prior to publication of the ANPR in the Federa 1 Reaister. i Executive Order 12044 Moreover, President Carter has explicitly recognized the desirabiiitv of an ANPR. In his Executive Order 12044, he stated that "[ajgencies shall give the public an early and meaningful opportunity to participate in che development of agency regulations," and he listed as one means of accomplishing this objective: "publishing an advance notice of proposed rulemaking." (43 Fed. Reg. 12662 (Mar. 24, 1978).) Imoact L'Dcn Trade Secrets and International Trade The reasoned analysis that could be triggered by your agencies' publication of an ANPR is also essential because your regulation could have an adverse impact both updn the national economy through erosion of competitive trade secrets, and upon the balance of payments as affected by the markstability of U.S. goods abroad under the new trading patterns initiated this year by the completion of the Multilateral Trade Negotiations, and. by the Standards Agreement set forth in Title IV of the Trade Agreemeni Act of 1979, Pub. L. No. 96-39 (July 26, 1979). Briefly stated, Title IV expressly requires your agencies to consider thoroughly the international impact of your contemplated Labeling regulation. ly In 1975, CSrlA published an ANPR concerning confined spaces rulemaking (40 Fed. Reg 3C980 (July 24, 197^)), and received 107 responses to char ANPR. Early in 1979 OSHA circulated draft of a new .ANPR, and late in 1979 published the ANPR. (44 F ed . ?. eg 60333 (Oct. 19, 1979), corrected at 44 Fed. P.ec . 64C9 5 ( No v . 6 , 19 7 9).) a S4L 000?24e6 3ir.cr.di-n arc --. 3 _ e sec'.ic n 451(13) of Title IV defires "star.clard" as m- clucinc "[specifications relating to .he . . . la're^ir.g rsquirsnarr aoolicable to a orocuci. " Section 401 requires that! a sea r.d arts- reiaced activity serve a "demonstrable purpose", protecting ''legit imate health o saretv id j actives Th.a 1 eats iati v<i 'nistor/ of the Act defines "demonstrabia purpose" as something thag is "capable of being shown or proved". Thus, "a mere statement of the purpose is insufficient to meet this test -- there must be a reasonable shewing that the activity indeed is designed and operates to serve a legitimate domestic objective.." The phrase legitimate domestic objective "is to be interpreted in full actcrdar.ce with the recognized existing authority of . . . Fed'erai agencies . . . in the standards area." (Report of the Committee on Ways and Means of the House of Representatives on Trade (Agreements Act of 1979, H.R. Rep. No. 317, 96th Cong., 1st Sess. 113 (1979).) As noted supra at 1, there is no recognition of -- (indeed, there is a substantial dispute as to -- your agencies' authority to embark upon labeling rulemaking on an omnibus basii. Section 402(3) provides that "[ejach Federal agency shall, if appropriate, develop standards based on. performance criteria . . . rather than on design criteria . . . " We urge that any labeling rule comport with the Act's preference for performance-based rulemaking. Section 402( 2) (A) provides that "each Federal agency, in developing standards, shall take into consideration international standards and shall, if appropriate, base the standards on inter national standards." An A17PR is necessary to ensure that appro priate consideration is given to international labeling activities. Section 402( 2) (3) does not alter the requirement that international standards be considered, but does state that the protection of human health or safety (to the extent this requires labeling) ia a permissible reason for deciding not :o implement an intar national standard. Section 414 provides for the establishment of a "stand ards information center", the function of which is to "serve as the central national collection facility for standards . . . whether such standards . . . are . . . domestic oir . . . interna tional . . . . " The Act is expected to become effective on January 1 i960, and the standards information center therefore has not yet been established. We explained above that Ti le IV, requiring as it dees review of internacional labeling activ ities , underscores th e nLecessity of publishing an ANPR to ascertain he status of pending and existing international labeling agreements, The current information obtained from the AN?R also would be of cons iderabie ass isranee no the Secretary of Commerce, who is r squired by 3 ecti.on 414(a) to maintain the standards informal ion center. SAL 000022487 r-1 . 31 r.ghar ar.d a- _a 10 137? As explained above, the cono emplated regulation could have a substantial adverse effect upon the national economy and upon the marketability of LT.S. products abroad. We are therefore providing a copv of this letter to the Chairman of the Senate Finance Committee and the Chairman of the House Ways and Means Committee. Similarly, we are providing a copy of this letter to the President's Special Representative for Trace Negotiations, the Chairman of the Regulatory Analysis Review Group, the Acting Secretary of Commerce, the Director of the Council on Wage and Price Stability, the Director of the Office of Management and 3udget, and the Director of the Regulatory Council. If you should have any questions regarding the necessity of publishing an ANPR on labeling, please do not hesitate to contact SOCMA's Washington office (telephone: 202-659-0060). Sincerely yours, JLJ CX - Ronald A. Lang Executive Director SYNTHETIC ORGANIC CHEMICAL MANUFACTURERS ASSOCIATION, INC. cc: Hon. Russell 3. Long Chairman, Senate Finance Committee Hon. Ai Oilman Chairman, House Ways and Means Committee Hon. Reubin O'D. Askew Special Representative Trad e Negotiations for Hon. George C. Eads Chairman, Regulatory Analysis Review Group Hon. Luther H. Hodges Acting Secretary o'f Commerce Hon. Alfred E. Kahn Chairman, Council on Wage and Price Stability Hon. James. T. McIntyre, Jr. Director, Office of Management and Budget Mr. Peter Petkas Director, Regulatory Council 000022483 SAL *>xc5; ;.3*fVy c * - . ^ '<' OV ca -a**r-A,, nc***ahj*. >' *-M ~ :C - C A^ C3MA* >.*" A.IC 3-*- - ,fC3 - -54C3 >- ,*<5*** (iWCfiTT .U(, Oy`t .IU^ S'*I'S3ut <A'.:s a . ..ta (3*ta3r >c. a58-*3^'rr jGPiC ^wCAT *fl a w( 5J <1 9i.SCtS*%HSi*5C^'0N* m v * <;%. C-iC. OvO*" HC 9 ^.CvtBiC. UAM T3*0^. Cmaao o.COA*t* rraCb*^C0I rv: 9C?0t**C5_'^ 13WC* 3IWBLiAl X0-3. .LvAtal ts<ON ww* UVIM3ITQN. v -3- ** f j 8.*:3w3- tc0o9-(*8*^'9 5*CS - A^.CN 3av3 5 JC a .O-l I . C-s C 3 j" -kb :e i-3:vo^acc,iuc*^^rcrb(j ,,o - * j ;:< * ;s 9a<*3m "vfr HC89C3' 3h aO> va*CCa9taA C~" ** * A^3jOn(jB. W'C *C. 1 -QB**S JQNA^*-S a K.Mt C f'ON #c cZsZ(a^ ^+ BsQ S3A^:%ct* 5*y.3 n. aacw-n *wv J. *aO w *v C ANO|> a>. S;s3 ausscu - N.c- 0-. A 3 -* Ct.) DvO*A*NCNA30rT.0A-f0lCC-*C*w.45<.a* * Ctt a Covington & Bulling 883 SIXTEENTH STS E r.| M. W. WASHINGTON, O. C, 2 0 0 0 3 qU&, TtLlxONt ;a02l *S2'SOOO WRITER'S OiRECT OlAL NU"9C^ (202) 452-60001 NrW(lL *. tLViO" *N . T-O-A *Wl*tC fQhfAiNC a. |8a3iCT C3MA40 Kw Bli Nfi, jm. Hgw*B3 c. --cifACdfl JAN C S - C*\. A KI* JOHN COC<" r-iiv il fi AJiigeot tcuc* <)) Olw4' C9wW0 Oc to be j: 26, 1979 The Honorable Douglas M. Costle Administrator U.S. Environmental 401 M Street, S.W. Protection Agency Washington, D.C. 20460 i I , | Re: Labeling Regulations for iAdustrial Chemicals UnderTSCA I Dear Mr. Costle: j This firm represents- the Chemical Manufacturers Association (CMA), a trade association whose member companies account for more than 90 percent of the total production capacity for basic industrial chemicals in the]United States. We are writing about an issue of great concern to the chemical industry -- the promulgation of hazard-related I labeling requirements for industrial chemicals under thA Toxic Sub stances Control Act (TSCA) . According to receht pressaccounts, the Environmental Protection Agency tEPA) and the Occupational Safety and Health Administration (0SHA) are now proceeding with a joint program to develop such labeling requirements and intend to publish proposed ru|es on the sub ject in the next few months. | CMA *s members are committed to providing their employees and customers with adequate information concern ing the safe use of chemicals. Together with its member companies, CMA has participated actively in developing and implementing voluntary labeling programs to achieve this objective. Based on its expertise and experieAce, CMA stands ready to assist EPA in developing labeling regu lations under TSCA which have similar aims. Irldeed, CMA has already offered such assistance to the Agency in a letter $M- 248*3 |00Z OVINC-TON & S w' P ! M G The Honorable Douglas M. Costle October 26, 1979 Page Two dated July 6, 1979 which was addressed jointly td you and Dr. Bingham of OSHA. At the same time, CMA strongly believes that any labeling requirements which EPA adopts must comport fully with the requirements of TSCA. Recent press accounts of public statements by certain EPA officials indicate that, in its current deliberations, the Agency may not be devoting sufficient attention to applicable statutory provisions. Accordingly, before the rulemaking process progresses any further, we wish to direct EPA's attention to certain basic principles, derived from the text and legislative history of TSCA, to which any EPA labeling proposal must conform. These principles, we believe, provide the basic framework within which EPA's labeling rules must be developed, 1. Definition of Unreasonable Risk The central issue which any labeling proposal must address is the criteria for imposing labeling requirements. EPA must develop principles for determining which chemicals will be labeled, which manufacturers and processdrs of those chemicals will be subject to labeling requirements, and what level of risk must be presented before those labeling require ments come into play. In examining these questions, EPA must be guided by Section 6(a) of TSCA, from which the Agency's authority to require labeling derives. Under Section 6(a)(3), EPA may promulgate rules directing that a substance or mixture "be marked with or accompanied by clear and adequate warnings and instructions with respect to its use, distribution and com merce, or disposal ..." As specified by Section 6(a), the. precondition for imposing such requirements is a finding that "there is a reasonable basis to conclude" that the chemical substance or mixture in question presents or will present "an unreasonable risk of injury to health or the environment." In determining whether such a risk exists, EPA must be guided by Section 6(c), which requires it to consider., and publish a statement with respect to, four factors before promulgating a rule under Section 6(a) : the effects of the chemical on health and the environment, the magnitude of human and Environmental exposure to the chemical, the chemical's benefits for various uses and the availability of substitutes for those uses, and the probable economic effect of EPA's proposed ajction, in cluding its impact on small business and technological 2Z^90 qOOQ sM- COVINGTON S SPRUNG The Honorable Douglas M. Costle October 26, 1979 Page Three innovation. Thus, EPA must weigh the potenti4l harm associated with the specific chemical against the adverse economic and social impact of regulatory requirements. | These provisions have a number of important impli cations for any labeling rules which EPA adopts under Section 6(a)(3). I First, EPA cannot promulgate labelirjg requirements for a chemical which, under its actual conditions of use and exposure, poses no risk or a risk that is insubstantial. Rather, the statute requires a finding of "unreasonable risk" as a prerequisite to labeling requirements.- Thus, EPA must make some showing that, absent labeling instructions concern ing safe use of a chemical, that chemical will cause signifi cant harm to humans, the environment or both. I EPA is not em powered to require labeling information which relates to hazards which are purely theoretical or to hazards which, in view of a chemical's uses and exposure, are remote and of little prac tical concern. Moreover, since the concept of 'unreasonable risk" involves a balancing of costs and benefi'ts, the Agency must show that, for the chemical in question, the harm which labeling will prevent outweighs the expense ankd effort that labeling requirements will entail. If labelincg a particular chemical will provide small benefits and imposte large burdens, .EPA cannot require that labeling under Section 6 There is an important corollary to t]hese principles which must shape the procedures that EPA utili:zes to determine whether there is an "unreasonable risk" for wh.ich labeling can be required. Because risk is a function of the properties, uses and exposure patterns associated with a particular chemi cal, EPA cannot adopt omnibus labeling require ments which ap- ply to a broad and non-specific chemical class Rather, the Agency must present evidence concerning the alleged risks of each chemical proposed for labeling requirements, and industry must have a meaningful opportunity to comment on that evidence and respond with evidence of its| own. With out a procedure which provides for these factual determinations concerning specific chemicals, the careful balancing test which underlies the Congressional concept of "unreasonable risk" could not be applied, and EPA's labeling] requirements would be legally defective. SAL 000022491 ovin'gton & euPLiNG he Honorable Douglas M. Costle October 26, 1379 Page Four While an omnibus proceeding covering all or most industrial chemicals would be beyond EPA's statutory author ity, a two-stage approach to developing labeling rules could be utilized that would satisfy statutory requirements. Dur ing the first stage of this process, EPA could develop a "prototype" labeling rule which (1) defines the different types and degrees of hazard which would trigger labeling obligations, and (2) for each such hazard, prescribes appro priate warnings and instructions and specifies methods for their dissemination. Once EPA has established the basic standards and procedures for labeling requirement the Agency would then apply these standards and procedures t d particular chemicals. This task would necessarily entail se parate rule- making proceedings for particular chemicals and, where appro- priate, for chemical categories which are suffici ently narrow to satisfy Section 26 (c) of TSCA. The focus of s uch proceed- ings would be on whether the basic statutory crit erion of "unreasonable risk" has been met for a particular chemical in. view of that chemical's specific properties, uses and exposure. CMA would be willing to work with EPA ifi develop ing an appropriate "prototype" labeling rule under Section 6. It believes that the existing standard of the American National Standards Institute (ANSI) provides a useful poinr of de parture for acute hazard labeling and could be restructured to embody the statutory concept of "unreasonable risk." It must be clearly understood, however, that such a rule would merely serve as a "model" for subsequent proceedings, and these later proceedings would provide for a full Considera tion of the unique facts which relate to individual chemicals. 2. The Importance of Minimizing Regulatory Burdens Complemented by Section 2 of TSCA, Section 6 directs EPA to act prudently and responsibly, with constant and careful attention to the economic consequences of its regulatory decisions. Rules which EPA issues under Section 6(a) must prescribe the "least burdensome requirements" possible, while Section 6(c) directs EPA to make findings concerning the "reasonably ascertainable economic consequences" of any rule that it proposes to adopt. Similarly Section 2(b)(3) of the Act directs EPA to exercise its authority "in such a manner as not to impede unduly or create unnecessay economic barriers to technological innovation." Sec tion 2 (c) amplifies this policy by providing that it is SAL OC0022492 OviN-GTON BUR'.ING The Honorable Douglas M. Costle October 26, 1979 Page Five "the intent of Congress that [EPA] shall carry out this Act in a reasonable and prudent manner* and by directing EPA to "consider the environmental, economic,! and social impact of any action the Administrator takes 'or proposes to take under this Act-" These statutory provisions must be brought to bear on any labeling program which EPA proposes. First, the Agency must devote careful consideration to - - and attempt to minimize -- the potentially massive costs of making detailed labeling information available at near ly every level of a chemical's distribution process, includi \g its sites of manufacture, processing and disposal. If there .are alternative communications tools which can minimize these costs and lessen the overall burden of 'compliance without jeopardizing the goals of the Agency's labeling effort, these alternative tools must form the basis of any EPA rule under Section 6(a)(3). Equally important, EPA has a responsibility to avoid labeling requirements which place an unwarranted stigma cn particular chemical's by exaggerating or misrepresenting the potential risks which they pose. For this reason, every effort must be made to utilize a labeling terminology and format which accurately convey the severity and likelihood of any injury which particular chemicals can cause. The need for a balanced presentation of potential risks is particularly great with respect to "Chronic" hazards like carcinogenicity, mutagenicity and teratogenicity. In designing labeling requirements, EPA must take into account the substantial- scientific uncertainty involved in identify ing chemicals which can cause these effects. It must also take into account the disparate levels, of risk which different chemicals pose depending on such factors as tijieir innate properties, potency, uses and conditions of exposure. Signi ficantly, in its recent policy concerning the I regulation of chemical carcinogens, the Regulatory Council ^tressed the importance of these considerations, indicating that any analysis of a substance's carcinogenic potential involves a "characterization of the extent and quality of the evidence supporting this determination" and an assessment of "the size of the exposed population", "exposure sources, routes, and conditions, the duration, frequency and intensity of exposure, and the relevant characteristics (e.g., age, ^ex, health) of 002*4 93 O VI S'O TO N B'J^UNG The Honorable Douglas M. Costle October 26 , 1979 Page Six the exposed population." 44 Fed. Reg. 60038, 60040 (October 17, 1979). Any EPA labeling program under TSCA which does not convey information concerning these matters would be incomplete and misleading. EPA's goal should be to encourage informed and balanced decisions about chemicals by manufacturers, dis tributors, processors and workers. An approach which fails to place potential risks in proper perspective and causes undue alarm and disruption among users of chemicals would constitute poor public policy, discriminatory agency action and a violation of the requirements of TSCA. 3. Disclosure of Chemical Composition. Over the past several months, some groups have apparently advocated requiring all manufacturers and distrib utors of chemicals covered by TSCA to disclose the precise composition of those chemicals to their users, including exposed members of the workforce. In the case of "substances", this disclosure would involve the specific identity of the chemical. In the case of "mixtures", disclosure would involve listing the constituent substances of the chemical and the relative quantities in which those substances are present. TSCA does not authorize EPA to require such an across-the-board disclosure of chemical composition. Under Section 6(a)(3), the Agency may require manufacturers and distributors to provide labeling information for one purpose only -- to afford protection against "unreasonable risks" within the meaning of Section 6(a). In view of this purpose, EPA cannot require the routine disclosure of chemical composi tion for all chemicals. Rather, such disclosure can only occur on a selective basis and must be tied to a determination that (1) the chemical in question presents an "unreasonable risk", and (2) that risk can be reduced or eliminated if users of the chemical are informed, of its precise composition. The situations where this test is satisfied will be the infrequent exception, not the norm. 4. Confidentiality Any labeling program which requires the disclosure of chemical composition must also provide full protection for 0C002249A SAL .OvinG'ON & 0UP'_'ng The Honorable Douglas M. Costle October 2 6, 1979 Page Seven confidential business information. Frequently, the specific identity of a substance or the precise contents of a mixture is a valuable "trade secret" whose disclosure will enable competitiors to market products with identical properties and characteristics. In this situation, it is common for manu facturers to describe the chemical to customers and users in "generic" terms and to withhold more precise information about its composition in order to prevent competitive harm. Under Section 14 of TSCA and 18 U.S.C. 1905, EPA has no authority to compel departures from tijiis customary industry practice. Section 14(a) forbids EPA, except in cer tain limited circumstances, from disclosing Information that falls within Exemption 4 of the Freedom of Information Act, 5 U.S.C. 552(b)(4). This exemption applies to "trade secrets and commercial or confidential information obtained from a person and privileged or confidential." Sim|lar obligations are placed on EPA by 18 U.S.C. 1905 , which I requires all federal agencies to safeguard trade secrets. Section 14(b) creates a narrow exemption from EPA's duty td> withhold com petitively sensitive information for "any health and safety study" submitted to the Agency. Clearly, however, labeling information covered by- a Section 6(a) (3) rule could not be considered part of a "health and safety study." Moreover, Section 14 (b) does not permit EPA to compel disclosure of confidential procedures used in manufacturing or processing a chemical or the portion of a mixture comprised by its com ponent chemical substances. Much of the information concern ing chemical composition which EPA's labeling rules might encompass would clearly fall in this category. This informa tion would still be immune from disclosure eyen if Section 14 (b)'s exemption for "health and safety studies" were to apply It is true that Section 14(a) (4) permits EPA to require the disclosure of confidential commercial information when "necessary to protect health or the environment against an unreasonable risk of injury ..." CMA questions, however, whether the disclosure of precise information concerning chemical composition will ever be "necessary1! within the meaning of this provision. Instructions concerning proper use and handling of a chemical, augmented by a "generic" description of its composition, will be sufficient to enable the chemical's users to protect exposed persons. For this reason, a more precise description of the chemical's- identity ooocz^95 SAL 0^'S'G'OM & BULLING The Honorable Douglas M. Costle October 26, 1979 Page Eight would not add to the goal of safe chemical use. Since an adequate labeling program can be developed withijsiut dis closing the precise composition of the chemical it covers, EPA has no authority under TSCA to require such disclosure where it would compromise the protection of tracjl e secret information. The above principles provide a necessary legal framework for any labeling program which EPA proposes under Section 6 of TSCA. If the Agency conforms to these prin ciples, we believe that it can develop a labeling proposal which is constructive, effective and in keeping with statu tory requirements. Within the basic legal framework outlined in this letter, CMA stands ready to assist the Agency in formulating the particulars of such a labeling proposal. The undersigned and other CMA representatives would be happy to discuss this matter further with you or your staff on a mutually convenient date. 1 In conclusion, we wish to emphasize th at any industry-wide labeling program that EPA adopts \J?ould be a massive undertaking which involves substantial ost and effort by industry and significant long-term ef ects on the attitudes of those who make and use chemicals, Any program of this scope and impact deserves the most care fful consideration by all concerned. Peter Barton V. utt cc: Dr. Eula Bingham Steven Jellinek John DeKany Cynthia Kelly Flo H. Ryer Dr. George M. Semeniuk Richard Denney, Jr., Esq. Robert M. Susdman SAL 000022496 BY-LAWS OF THE AMERICAN CONFERENCE ON CHEMICAL LABE ING* ARTICLE I Name. The name of the organization shall be the American Conference on Chemical Labeling, hereinaf ter the "Conference." ARTICLE II Membership Section 1. Membership in the Conference shall be available to those persons affiliated with the business sector whose job responsibilities or professional interests include precautionary labeling or hazard information communication of chemicals. Section 2. The only obligations c|f members shall be to attend meetings of the Conference and to conduct themselves in accordance with the purposes of the Cc nference. Section 3. Persons who qualify under Section 1 of this Article shall be deemed members df the Conference upon presentation of a written request fdr membership to the Chairman of the Conference or his dedignee, except that persons in attendance at the preliminary organiza tional meeting or the formal organizational meeting of the Conference, and who are otherwise eligible for membership, shall be deemed members unless they decline such member ship in writing to the Chairman of the Conference or his designee. Section 4. Only members, or guests invited by or given the permission of the chairman or his designee, may attend meetings of the Conference. ARTICLE III Purpose. The purposes of the Conference shall be: Section 1. To provide a forum in'which persons engaged in the precautionary labeling and hazard informa tion communication of chemicals can meet for appropriate discussion of their mutual professional interests; * Language in brackets is for approval by the members at the first meeting of the Conference following the formal organizational meeting. SAL 000022497 2- - Section 2. To maintain current expertise in pre cautionary labeling and hazard information communication and to foster the development of such expertise; and Section 3. As deemed appropriate by the Conference to serve as a resource to any responsible group that wishes to avail itself of the expertise represented in the Conference. ARTICLE IV Procedures for the Election of Officers and Conduct of Business. Section 1. At''.the formal organizational, meeting: (a) The members shall elecj^a temporary Chairman and vice chairman and adopt by-laws on \ tw<p^-lfhirds (2/3rds) vote of the member&^present and shall trans act other J^dsine^s on a majority vote of the roembers pr^se^it? (b) tire temporary Chairman shall appoint a Nominating Committee. Section -At--the--first mooting-of the Conference frJJl n rj hhp f-Artnnl nrij.ini mnntring the members Shall elect, by a two-thirds vote of a quorum of the members pre sent, a Chairman, Vice Chairman, [and Secretary]* from among nominees presented by the Nominating Committee. Section [A quorum for the purpose of trans acting business <sffor '-the" roFirreil organisational shall be one-fourth (1/4) of the full membership and all actions shall be taken by majority vote of a quorum present]* except that the election [or removal]* of officers and amendment of the By-Laws shall be by a two-thirds (.2/3) vote of such quorum. [Section j. Meetings of the membership shall be called by the Chairman upon such notice as he deems appro priate . ] * [Section Meetings of Conference committees shall be called by the respective Chairmen of those committees upon such notice as they deem appropriate.]* -3ARTICLE V Officers. Section 1. The Chairman, Vice Chai rman [and Secretary] of the Conference shall each serve a two ( 2) year term of office [and may be reelected]*. Section 2. It shall be the respons ibility of the Chairman to plan and preside at meetings.o f. the Conference according to Robert's Rules of Order and. t o appoint such Committees and Committee members as he dee ms appropriate for the purposes of the Conference. Section 3. It shall be the respons ibility of the Vice Chairman to serve in the absence of t he Chairman, to serve any unexpired term of the Chairman should that office become vacant for any reason, and t o perform such duties as may be directed by the Chairman. Section 4. It shall be the respons ibility of the Secretary to record the minutes of the mee tings of the Conference, to prepare agendas and announc ements of meetings, and to maintain an accurate list of member s. [Section 5]*. The members may reimb urse the Chairman, and the Vice Chairman when serving as Chai rman, for actual expenses incurred in the performance of hi s duties. 1/10/80 :jj SAL 000022499 1 I SAL 00G0225C1 2!3A AMERICAN COUNCIL ON SCIENCE AND HEALTH America's Health: E A Century of Progress E But A Time of Despair E SAL 000022502 The Arnerican Council on Science and Health (ACSH) is a national consumer education association directed and advised by a panel of scientists from a variety of disciplines. ACSH is committed to provid ing consumers with scientifically balanced evalua tions of issues relating to food, chemicals, the envi ronment and health. ACSH is a nonprofit association exempt from federal income tax under Section 501 (c) (3} of the Internal Revenue Code. All contributions are tax-deductible as provided by law. Individual copies of this report are available at a cost of $2. Prices for 10 or more copies are available on request. November 1983 This report on health n the United States was writ ten by Cathy Becker Popescu, M.S.. a Research Associate with the American Council on Science and Health. i ACSH gratefully acknowledges the comments and contributions of the following individuals who reviewed this report] Roslyn B. Alfin-Slatbr, Ph.D. University of California, Los Angeles Lewis A. Barness, Ivl.D. University of South Florida College of Medicine Stephen Barrett, M.D. Lehigh Valley Committee Against Health Fraud Julius M. Coon, M.D., Ph.D. Thomas Jefferson lllniversity Merril Eisenbud, Sc^D. New York University Medical Center Dean C. Fletcher, Ph.D Washington State University Ralph W. Fogleman, D.V.M. Upper Black Eddy, Pennsylvania LaNelle E. Geddes, Ph.D., R.N. Purdue University Richard A. Greenberg, Ph.D. American Council bn Science and Health William R. Havender, Ph.D. Berkeley, California Victor Herbert, M.D., J.D. Bronx Veterans Ac ministration Medical Center State University of New York William T. Jarvis, Ph.D. Loma Linda University David Kritchevsky, Ph.D. The Wistar Institute, Philadelphia Manfred Kroger, Ph.D. Pennsylvania Statle University Howard D. Maccabee, Ph.D., M.D. Radiation Oncology Center Walnut Creek, Ca lifornia Charles D. May, M.D. Quechee, Vermont Kathleen A. Meister, M.S. American Council on Science and Health Joseph M. Miller, M.D. New Hampton, New Hampshire Sidney Shindell, M.D., LL.B. Medical College of Wisconsin Fredrick J. Stare, M.D., Ph.D. Harvard School of Public Health Stephen S. Sternberg, M.D. Memorial Sloan-Kettering Cancer Center Elizabeth M. Whelan, Sc.D., M.P.H. American Council on Science and Health James Harvey Young, Ph.D. Emory University The opinions expressed in ACSH publications do not necessarily represent the views of ail ACSH Direc tors and Advisors. ACSH thanks Dr. Merril Eisenbud for allowing us to borrow the title of this report from a speech and article written by him ("The Environment, Technology and Health: A Century of Progress But A Time of Despair", American Journal ofMedicine, April 1980). "It is extraordinary that we have just now become convinced of our bad health, our constant jeopardy of disease and death, at the very time when facts should be telling us the opposite. In a more rational world, you'd think we would be staging bicentennial ceremo nies for the celebration of our general good shape. In the year 1974, out of a population of around 220 million, only 1.9 million died, or just under one percent -- not at all a discouraging record once you accept the fact of mortality itself. . . . , . Despite the persisting roster of still unresolved major diseases -- cancer, heart disease, stroke, etc. -- most of us have a clear, unimpeded run at a longer and healthier lifetime than could have been foreseen by any earlier generation." Lewis Thomas in Notes of a BiologyWatcher: The Health Care System, New England Journal of Medicine 293, December 11,1975 2 c|IONTENTS INTRODUCTION ....................................... HOW HEALTH IS MEASURED........... LIFE EXPECTANCY1................................. DEATH RATE ............................................ AMERICANS ASSESS THEIR HEALTH INFECTIOUS DISEASES ...................... LEADING CAUSES OF DEATH Heart Disease and Stroke Cancer .. . . L.................................... Accidents . . j. . . . . . . . . . . . . . . . . . Chronic Obstructive Pulmonary Disease...................... THE HEALTH STATUS OF AMERICANS IN DIFFERENT WGE GROUPS ____ The Health of American Infants The Health of American Children The Health of1 Adolescents and Young Adults................................. The Health o4 American Adults . . The Health of Older Americans . PREVENTING PREVENTABLE DEATHS CONCLUSION .1....................................... REFERENCES . 3 5 5 8 8 9 10 n 13 14 14 14 15 18 20 20 23 25 26 27 INTRODUCTION A membership and fundraising appeal by a wellknown consumer ^roup began with the following words: "Earlier generations lived in fear of polio and smaJJpox, Nowodloys the most deadly epidemics are manmade" (Ref. ). The apparent intent of these statements is to sug gest that modern lifestyle and technology are respon sible for on equivalent (or perhaps even greater) amount of death imd disease as were past epidemics of poliomyelitis and smallpox. Similar allegations that the health of Americans has deteriorated due to poor dietary habits anid exposure to man-made products, such as food additives, pesticides and pollutants, abound in popular books and articles. The authors of I------------.J......................(. r--- ii.. 3 SAL 000022504 and television programs, spreading their message of gloom and doom even further. It is no wonder that much of the American public believes that the nation's health has never been worse. As scientist and author Lewis Thomas has said "The new danger to our well-being, if we continue to* listen to all the talk, is in becoming a nation of healthy hypochondriacs, living gingerly, worrying ourselves half to death" (11). Yet, according to the health statistics, Americans are healthier than ever before. Modern technology and lifestyle have drastically reduced the health haz ards to which we are exposed, rather than increasing them. In 1900, approximately 100 out of every 1,000 infants born in the United States died before their first birthday; today fewer than 12 out of every 1,000 infants fail to survive their first year. An American born today can be expected to live an average of 27 years longer than someone born in 1900. The age-adjusted1 2 * * death rate declined 53% from 1900 to 1950, and another 27% from 1950 to 1977. The death rate from infectious diseases has plum meted to record lows in this century. With the reduc tion of infectious disease mortality, many more people now live to an age where they are subject to chronic diseases, such as cancer and heart disease. Conse quently, chronic diseases now account for a much larger proportion of deaths than they did at the turn of the century. Even the death rate from heart disease, the lead ing cause of death in the United States, has declined significantly within the past 30 years or so. The death rate from cerebrovascular disease (stroke) has also decreased. There has been a gradual decline since the 1930s in the age-adjusted cancer death rates (except ing lung and skin cancer) for Americans under the age of 65. The bottom line is that Americans have never been healthier. Certainly, there is much room for improve ment, but with a few specific exceptions, the techno logical and lifestyle changes which have occurred in the past eight decades have improved, rather than harmed, Americans' health. HOW HEALTH 1^ MEASURED The health status of a population can be measured in several ways. Tht most commonly used measure ments are those relating to mortality, such as life expectancy and death rates. Information on mortality i_,s f_a_i_r_ly__a__c_c_u_r_ate, is. easy to obtain from death records, and comparable historical and international informa tion is often available. Information about the incidence or prevalence of illness (morbidity) is more difficult to obtain. Although physicians are required to report some diseases (mainly those that ere infectious) to the Centers for Disease Control, mbst illnesses ore not recorded in any central registry. i The morbidity information available from research studies, medical reports and national surveys is often difficult to ir terpret, especially when compari sons are made over time or between countries. For example, an increake in the prevalence of a disease may mean only that diagnosis has improved over the years. Similarly, a h gh rate of reported illness in one country may simply reflect the fact that diagnosis is more accurate therd than in other nations. LIFE EXPECTANCY Life expectancy1 is the average number of years of life remaining to ind ividuals of a given age. The most common measure o; life expectancy is the number of years which the ave age newborn can be expected to live. During this centbry, there have been dramatic gains in this important health index (Table 1). In 1900, the average newborn could be expected to live only 47 years (7), whereis a child born today can be expected to live 74.5 years5. The gains in life expect ancy were especially evident in the first half of the century, and were largely attributable to the control of infectious and parasjitic diseases, which were major killers of the young (]6). 1 Age-adjustment is a method ofcalculating mortality and/ or incidence rates in order to remove the confounding effect due to the age distribution of a population. Such procedures are required to compare death and disease rotes for popu lations whose age compositions may differ due to time or geography. 2 U.S. Dept, of Heal\h and Human Services, Public Health Service, Office of Health Research, Statistics and Technol ogy, National Center for Health Statistics, Annual Summary of Births, Deaths, Marriages ond Divorces, United States: 1982, Monthly Vital Statistics Reports, 31 (13), 1983. 45 SAL 000022505 It is not just the young who hove benefited from an increased life expectancy. Within the past 30 years, adults have realized greater gains in life expectancy than have infants. From 1900 to 1 950, life expectancy at birth increased 38%, while the life expectancy of a 45 year-old person rose only 15%. From 1950 to 1980, however, life expectancy at birth increased 8%, whereas life expectancy at age 45 increased 13% (9)_ This appears to be a major reversal of an historical trend which may be due, in large part, to the recent drop in deaths due to cardiovascular disease. In spite of the increases in life expectancy, the maximum life span of Americans has not increased, probably because there is a biological limit to life span. Population statistics suggest that under ideal societal conditions, the average age of death would be approximately 85 years (7). During this century, Americans have rapidly approached that ideal. In 1900, the average person died 38 years "prema turely", 17 years "prematurely" in 1 950 and only 12 years "prematurely" in 1980, Moreover, violent death accounts for three of the years by which we fall short of the ideal. 6 oc aiu O'o CNcnO'fOO'vnotq ^ n ~ m rt cs io o 05 CT> Eo CcD coLnoDcoa'vnLO^-T-| 05 < CNOJMCNCNMCNCnrt o v> o re Tr>e f0'5- a x: a E "O y-- OC &6 DO < a Z ID oLU >. Xc >- Q.CO u X-- LU O 05 iu< XQ_ Z u~> LU O z < x u , r*. Ln o --; m o 1 ^O'virsNW'-^ <o/> Q. Eoo CMLO'CM0'-- O'COCO OMv-i--U5'OinfVfi5d'0c'o0'oO'KdNri Q% 8i %--<2 x=<1 CO * o Xf LU eo o < 8O'oOr--'oOCS'OoCO'Oo'^''MOoD'Oo'O'rOov.O'OoO' CM CO CD n- CO o3 Q c O) S w 3TD o Vc) 'to 05 re C/5 'cc <o3 LU o cc 3 o C/D 7 00002^506 sM- DEATH RATE Perhaps most indicative of Americans' improved health is the declining death rate. The age-adjusted death rate decreased 53% between 1 900 and 1950 from 18 deaths to 8 deaths per 1,000 people per year From 1950 to 1977, the death rate fell another 27% t0 6 deaths per 1,000 people per year (6). In 1 982, less than 6 of every 1,000 Americans died3.4These decreases are especially remarkable when one con siders that a 100 percent decline in the death rate would mean that we had achieved immortality!" Major reductions in the death rate have occurred in all age, sex and race groups although some groups have benefited more than others. AMERICANS ASSESS THEIR HEALTH While self-assessment of health may be subjective, it has been found to correlate well with utilization of health care services and a physician's judgment of health status. When asked to rate their own health status in comparison with that of others within their age group, the vast majority (88%) of Americans say that their health is excellent or good. Only 12% of more than 100,000 individuals questioned in the 1978 National Health Interview Survey reported that their health was fair or poor (18). There is a marked tendency for people to perceive their health status as declining with age. In the 1978 survey, only 9% of young adults (17-44 years) said that their health was fair or poor, while 30% of those 65 and over rated their health as fair or poor (1 8). Those with low incomes are more likely to report fair or poor health than are those with higher incomes (18). 3 Ibid. 4 This observation was made by epidemiologist James Enstromina 1980 New York Times article. 8 INFECTIOUS DISEASES Many of the inf ectious diseases which once claimed the lives of thousands of Americans annually have decreased rer arkably in incidence and lethality due to improved sa nitary conditions, effective immunization and antimicr obial therapy. Deaths from in luenza and pneumonia declined from 200 per 100,C 00 people in 1900 to 31 per 100,000 in 1970. I 1 1900, 194 of every 100,000 peopie died from tuberculosis, compared to fewer than 3 in 1970. Similarly, c eaths from enteric (intestinal) dis eases dropped from 143 per 100,000 in 1900 to less than 1 in 1970 (4). Perhaps the most noteworthy example of the impact which immunization has had on health is polio myelitis. When a vaccine first became available in 1955, there were about 29,000 reported polio cases. Five years later the incidence had dropped to 3,000 and by 1975 only 8 cases were reported (19). As indicated in Figure 1, many infectious diseases which were once cd mmon among children have become increasing y rare due to widespread immunization. As the nu mb er of cases of these diseases has decreased, so has ih e number of deaths caused by their complications Unfortunately these dramatic reductions in morb idity and mortality have increased the visibility of the rare adverse effects of immunization, resulting in un warranted reluctance of some parents to have their ch ildren immunized. Since these childhood diseases hove not been eliminated, but merely controlled, Dy immunization, this could pose a serious threat to p ublic health. The incidence of one class of infectious disease -- sexually transmitted infections -- has increased in recent years. The number of reported gonorrhea cases rose about 12% from 1966 to 1973, and has since levelled off at about 1 million cases per year (17). There has alsi> been an increase in reported cases of syphilis since 1 977, with more than 31,000 primary and secondary infections occurring in 1981 (1 7). Genital herpes infections have become increas ingly common. It Is estimated that 500,000 to 1 million Americans are infected each year (13). More recently, there has been an outbreak of a new disease. Acquired Immunodeficiency Syndrome, or AIDS, which appears to be caused by an unidenti fied virus. As of Aulgust 1, 1983 approximately 2,000 cases of AIDS had been reported in the U.S. Nearly 40% of those affeclted had already died at that time (16). I 9 SAL 000022507 nscrswasar The disorder, which destroys a person's immune system, leaving him vulnerable to a variety of rare infections and malignancies, appears to be spread primarily through sexual contact and exposure to infected blood. Homosexual and bisexual men are most likely to be affected by AIDS (71 % of all cases). Intravenous drug users, hemophiliacs, and, possibly, Haitians are also at risk, A small number of cases of AIDS have been reported in recipients of blood trans fusions and in female sex partners of AIDS victims or those at high risk of AIDS (15). LEADING CAUSES OF DEATH At the turn of the century, most deaths resulted from infectious diseases. The age-adjusted death rate from influenza and pneumonia in 1 900 was equal to the present heart disease death rate and the death rates for tuberculosis and diarrheal diseases exceeded the present cancer death rate (20). The turn of the century population was subject to a much greater variety of potentially lethal illnesses than are today's citizens. Although the four leading causes of death accounted for only 40% of all deaths in 1 900, in 1977 they accounted for 71 % of ail deaths (20). 10 The leading ause of death in the U. S. today is heart disease. Cc ncer ranks second, stroke third, accidents fourth and ihronic obstructive pulmonary disease fifth (22). Li: ted in Table 2 are the death rates due to the 1 5 leading causes of death of Americans in 1979. Today's lead ing causes of death partially reflect the fact that more people in the United States are living longer. A qua rter of a century ago, only 8% of the population was 6 5 years of age or older. Today, close to 11 % of the pop ulation is in this age group, which is more prone to d velop and die from chronic diseose (6). Heart Disease and Stroke (Cardiovascular Disease) Heart disease, stroke and related disorders kill more Americans than all other causes of death com bined. In 1980, more than 1 million deaths -- 51% of all deaths for that year -- were attributable to these diseases (22). Infformation obtained from the 1972 National Health Interview Survey indicated that 2% of those under age 45 suffered from cardiovascular disease, while 9% cf those aged 45 to 64 and 20% of those 65 and old sr were affected (6). Despite the igh proportion of deaths due to cor diovascular dised se, the outlook is encouraging. Ageadjusted death ates from heart disease fell 1 8% in the 20 years from 1 950 to 1970 -- an average annual decrease of 1%. From 1970 through 1977, the heart disease death r a e dropped 2.6% per year. The reductions in age-adju sted heart disease mortality rates have been much greater for females than for males, particularly betv een 1950 and 1970, (6) Mortality rates from cerebrovascular disease (stroke) declined about 25% from 1 950 to 1970. In recent years, cerebrovascular disease death rates have continued to decrease more rapidly than have heart disease death rates (6). The improvement in cardiovascular disease death rates may be partially explained by improvements in medical treatmeit and care, but it is likely that other factors also conHbuted. Some possible explanations for the decline in heart disease and stroke mortality include: decreased cigarette smoking; improved detection and control of hypertension; decreased dietary intake of total calories and calories from fats; and increased emphasis on physical activity. It is diffi cult, however, tc quantitate the effect which any one, or a combination of these factors, may have had. it 000 02* 303 sM- TABLE 2. DEATH RATES AND PERCENT OF TOTAL DEATHS FOR THE 1 5 LEADING CAUSES OF DEATH: UNITED STATES, 1979 (Rates per 100,000 population) Rank Cause of death (Ninth Revision International Classification of Diseases, 1975) Rate Percent of total deaths All causes..................................... 869.5 100.00 1 Diseases of the heart................. 333.1 38.3 2 Cancer......................................... 183.3 21.1 3 Cerebrovascular disease (stroke) 77.0 8.9 4 Accidents and adverse effects . . 47,8 5.5 Motor vehicle accidents ......... 24.3 All other accidents and adverse effects .................... 23.5 5 Chronic obstructive pulmonary diseases and allied conditions . 22.7 2.6 6 Pneumonia and influenza........... 20.5 2.4 7 Diabetes mellitus ........................ 15.1 1.7 8 Chronic liver disease and cirrhosis ................................... 13.5 1.6 9 Atherosclerosis............................ 13.1 1.5 10 Suicide......................................... 12.4 1.4 11 Certain conditions originating around the time of childbirth . . 10.7 1.2 12 Homicide and legal intervention 10.2 1.2 13 Nephritis, nephrotic syndrome and nephrosis (disorders affecting the kidneys) ............. 7.1 0.8 14 Congenital anomalies (birth defects)..................................... 6.1 0.7 15 Blood poisoning.......................... 3.6 0.4 All other causes.......................... 93.3 10.7 Adapted from U.S. Dept, of Health and Human Services, Public Health Service, Office of Health Research, Statistics and Technology, Advance Report of Final Mortality Statis tics, 1 979, Monthly Vital Statistics Reports 31 (6), Supple ment, 1982. Cancer Contrary to popular belief, there is no evidence that America is experiencing a cancer epidemic. The American Cancer Society estimates that in 1983, some 440,000 Americans will die of cancer. (Of these, about 114,000 or 25% will die of lung cancer.) That may seem like an epidemic to some, but with the exceptions of lung and skin cancer (which are almost entirely self-induced), the age-adjusted cancer death rate among those under 65 declined slightly from 1933 to!977 (Figure 2). According to data from the Second and Third National Cancer Surveys (SNCS and TNCS), con ducted by the National Cancer Institute, the ageadjusted overall cancer incidence declined slightly from 1947 to 1971.5 Data from TNCS and a later sur vey, the Surveillance, Epidemiology and End Results program (SEER), are sometimes combined to support contentions of a recent increase in cancer incidence. Such a comparison is not valid, however, since SEER involves data collection and sampling methods which are quite different from those employed in the pre vious cancer incidence surveys. Although it is widely believed that the United States has an unusually high cancer death rate com pared with other countries, the data do not support this assumption. In a comparison of age-ad justed can cer death rates for 42 countries, the U.S. ranked 1 7th in male and 1 9th in female cancer death rates (Figure 3). 5 Data from the 1947-1948 Second National Cancer Survey and the 1969-1971 Third National Cancer Survey. 12 00002^509 sM- fc. !i^oilinr yi ' Figure 3; AGE-ADJUSTED WHItE VALE CANCER DEATH RATES PER 100000 POPULATION, SELECTED COUNTRIES. 1976-77 U'-guJv >.:c*iand Se-g-um NeirensruK r-enc. Ergidtt & WalM Ausina G#r*rnv FR Singapore tn'ft* Stares 0 SO 100 i SO 200 CSC JOO too JCC Numoer^ m irun oars 'nflicai* ' a^o^g 46 ccot'ines SOURCE: American Cancer Society. 1963 Cancer Each 4 Figures. New York, 1982 Accidents Accidents are the leading cause of death of Amer icans from the age of one through 38 (13). In 1979, more than 100,000 people died as a result of acci dents and adverse effects (22). The age-adjusted death rate among males was about three times the rate among females. Although there has been a slight upward trend in the death rate from motor vehicle accidents since 1975 (with an unexplained drop in 1982), the death rate from all other accidents and adverse effects has been decreasing gradually since 1 950. Chronic Obstructive Pulmonary Disease This category includes deaths from chronic bron chitis, emphysema and asthma. It accounted for nearly 50,000 deaths in the U.S. in 1979 (22). Approximately 85% of emphysema and chronic bron chitis deaths are attributable to smoking (10). THE HEALTH STATUS OF AMERICANS IN DIFFERENT AGE GROUPS It is a little misleading to examine only the health statistics for the population as a whole. There are sig nificant differences in the death rate, leading causes of death and general health status of different age groups. 14 The Health of American Infants At the turn of the century, about 100 of every 1,000 infants born in the United States died before their first birthday. By 1 959, fewer than 30 of every 1,000 infants failed to survive their first year (20). Progress in redu cing infant mortality has not been quite so dramatic in ecent years, although important gains have been ma :Je (Figure 4). The infant mortality rate remained fairly stable between 1950 and the mid 1960s, but it has agc|i in begun to decline rapidly in recent years, Betwe 1965 and 1979, the infant mortality rate fell nearly 50%. In 1982, there were slightly more than 11 infant deaths per 1,000 live births.4 There are markn d differences in the infant mortality rates for different groups within the U.S. The infant mortality rate for bla cks is nearly double that for whites (19). The U.S. infant mortality rate is higher than that reported in certain other industrialized nations (Figure 5). There are, however, significant differences in the manner in which infant mortality statistics are gath ered in the various countries. Thus, international com parisons of infant mortality rates may not accurately reflect survival differences among infants in different countries. For exam ale, Sweden and the Netherlands have consistently been ranked as having the lowest infant mortality rates. In Sweden, infants which do not breathe, but which display other signs of life ot birth, are registered as being stillborn and are excluded from infant mortalitv statistics. In the United States, on the other hand, such infants are declared as "live at birth" and their decths are included in the infant mor tality statistics. In the Netherlands, all infants who die before registration are excluded from birth or death statistics. Since it sometimes takes as long as a week to register an infant, many deaths may be omitted from the infant mortality statistics. In addition, all fetal deaths which occur after 20 weeks of gestation are recorded in the U.S , whereas in many European countries, only thos 2 fetuses who die after 28 weeks of gestation are registered. Nevertheless, the United States still has a higher infant mortality rate than some other countries, even when such factors are taken into consideration (5). There is some evidence that the higher incidence of low-birth weight (LBW) infants in the U.S. may be largely responsible for the higher rate of infant death here. When U.S. mortality rates in specific weight 6 U.S. Dept, of HealIth and Human Services, Annual Summary of Births, Deaths., Marriages and Divorces, United States: 1982. 15 sal 000C22510 groups were compared with those of corresponding weight groups of Swedish infants, the U.S. rates were consistently lower,even though Sweden has a lower overall infant mortality rate (20). Factors contributing to low birth weight include: poor maternal nutrition, maternal cigarette smoking, lack of prenatal care, poor physical condition and several specific diseases that are not related to pregnancy. The chances of an American infant being born alive have increased rapidly in recent years. Between 1 965 and 1977, fetal death rates declined 37% in whites and 45% in all other races (20). Other races still have much higher fetal death rates than do whites, however, due at least in part to differences in medical care, nutrition, etc. Recently, there appeared a widely publicized report indicating that the incidence of birth defects in the United States had doubled during the past 25 years. This report was based upon research done at the University of California, utilizing data obtained from the National Health Interview Survey. In that survey, parents were asked to describe any congenital physical, mental or behavioral disabilities which their children had. There was no attempt to verify the presence of the alleged "birth defects" from medical records. In addition, the diagnosis of "birth defects" such as learning and behavioral disabilities is influenced by the publicity which such disorders receive -- and by the absence of other, more overrid ing, health concerns, such as the complications of poliomyelitis or measles. Changes in such factors could account for an increase in diagnosis of these disorders in the absence of an increase in incidence. Researchers at the Centers for Disease Control (CDC), whose data collection methods are more con trolled and reliable than those used in surveys, have found no such generalized increase in physical deformities or chromosomal abnormalities in recent years (14). The CDC information is based upon hospi tal discharge records of several hundred thousand births from nearly 1,000 hospitals around the country. According to CDC, in 1 980 the number of children born with major defects, such as anencephaly and spina bifida, was less than expected bosed upon 1 9701973 rates. The incidence rates of some birth defects, such as those affecting the cardiovascular system, were higher than expected, but the rates of most defects remained essentially unchanged (14). 16 It is also of inte est to note that the University of California research ers found no increase in the number of children borrfi who were so severely impaired that they required i nstitutionalization. If there actually were a major increp se in the incidence of birth defects, one would expect that the rate of major, as well as less serious, birth defec's would have risen. Flgur lOO 90 _ Rant vortalitv fates, unted states SELECTED TEARS 191 5-197? NOTE '',v 1077 data are provisional data 1930 t9-0 1950 I960 1970 1900 I ottibc years ate Itnal Selectee years are i9'5. 1925, 1950. 197* SOURCE: U.S. Dept, of H al'h. Education and Welfare, Public Health Service Healthy People 1979 Figi e 5: to r- infant Mortality rates, selected countries. 1975 Uriiieo Stales recent year 51 data tcrCnile 1971 SOURCE: U.S. Dept, of H. olth, Education and Welfore, Public Health Service Healthy People 1979 17 SAL 000C2 2 511 The Health of American Children In 1900, 870 of every 100,000 children aged one through 14 died. By 1925, the death rate had fallen to 330, and by 1977, to 43 per 100,000 children per year (Figure 6}. One to four year-olds. Between 1950 and 1 979, the death rate among children aged one through four declined 53%, most of it attributable to a marked reduction in deaths due to natural causes (1 9). The death rate from motor vehicle accidents remained relatively stable, while fatalities due to other types of accidents fell 32% during this period (Figure 7). Deaths from pneumonia and influenza declined 89% in pre-school children from 1950 to 1979, with most of the decline occurring since 1960. Mortality from cancer dropped 57% and deaths due to congeni tal anomalies (birth defects) decreased 36% in these years (Figure 7). Five to 14 year-olds Since the late 1960s, more school-age children have died each year from acci dents and violence than from disease (Figure 8). His torically, non-motor vehicle accidents have been the single largest cause of death among the five to 14 year-olds. In recent years, fewer school-age children have died in such accidents and more have been killed in motor vehicle accidents, resulting in nearly equal death rates from these two causes since 1 970. Fire and drowning are responsible for the majority of non motor vehicle related accident deaths (19). Cancer has been the leading cause of diseaserelated deaths among five to 14 year-old children since 1950, with leukemia deaths being the most com mon. Although the leukemia death rote remained relatively stable from 1950 to 1 970, it fell significantly thereafter. The number of deaths due to congenital anomalies has also dropped sharply (19). 18 SAL 0CCC22512 ZISZZQOQO TVS iz '(6 L) sH*DaP J83udd asaq4 p Audlli ^d9j6 d joj junoaao J0DUDD |D4|U06 puo jsoajg SjUSpp^D ap|Lj0A jo^olu puo asDasrp 4_ioaq -- qjoap p sasnoa 6uipoa| 0M4 4xau aq4 ujojj so jaauoa ujouj aip dnoj6 aBD 5jLj4 u; uaujOM Auduj sd sawn jpq d pUD omj_ -apiains puD apiajwoq 'jaauo3 's4uappao BjaiqaA JO401U-UOU 'asDSsjp jJDaq Aq paMO||cq 'q4oap p asnoa Bu|pDS| aq4 9jd Sjuappao ep|q9A J0401U 'uauj 6uowy uaiuoM jo jDqj aai/vq s; usuj p a|DJ q4oap jpjaAo aqj_ -A4]|D4jouj u; saauaja^ip xas a6jD| qjd ajaqj^ `(61) s096L'P!uj 3H* aDuis pasDajaui qjoq aAoq 'dnojB a6o sjip ui qjDapp sasnDD 6ujpDa| ipjq puD q4-inoj aqj 'appjwoq puo app '!nS p^ddojp uaq4 puD sq^6 L a44 u! 5|3AS| iS3 -qBjq JjdL|4 paqaoaj sqnpD uoauauiv joj ssjoj A^!|Dpoiu 4uappay ( [ i ajn6i-j) a6o p sjoaA yy 04 gj sqnpo 6uolud qjoap p asnoa 6u|poa| aq. aJD S4uapiaay '!,[) dnoj6 a6o sjqi ui 4uaajad q uoq4 ajow pasoajaap osp sDq a^Dj qpap jaauoa aq^ '$<? [ aauis sq^Dap asoasip pDaq u; dcup 36jo| aqi 04 anp aq Adlu siq4 p qanw -QS6 [ aauis pjiq4 auo 41-ioqD pauipap aADq a6o p sjpaA yy 04 g s4|npD 6uolud S34DJ q4O0Q s^npD pp-.oaA pp 04 'dOlAJd $ 4l|caH =>]|qo<; 6/61 'ka*d puo uo.jDsnpj -Hi|oaH 1 idaa 'S'fl :33nOS //6i 0961 0S6I S26i 006i bjssjeoXbsipbiss |eu sA ibuio np to/ eiep ipusis.Aojd ejpsiep //6: 0961 0/6l 0961 0S6I 0P6l OC6I Q2M 0161 0061 3l0N 02 (o {. ajnBjj) SQ96 L SH* 6uunp asu 4q6;js o ja4jD q6nojq4 q/6 l luojj A||onuuo %i uoq4 9jooj pasDajDap S4|npo uojuaujv 0403 q4Dap aqj_ s(|npY UD3ijauiY }o qipapj aqj_ 'sasDasip pa44iiusuDJ4 A||Dnxas puo sapuouBajd pa4UDMun ?q4oap |D4uapp3D 04 a4nqiJ4UOD q^iqM 'asnqo Brup puo |oqo9|D ejo S4|npo BunoA 40 6uiaq-||aM aq4 04 S4oajq4 joJouj jaq40 (6L)sq4Dap ||D^o%g A|UO jnq 'sq4D8p pjn4Du o/09j jo^ 6u|4uno3DO 'pg^ [ ui qioap [Djniou p asno^ 6u;pDa| aq4 sdm jaDuo^j "(6 L) u9SU Aoq apoi ujoq puo apiDins 's4uapi9DD 04 anp sqjDap ajiqM 'A|4UODq;u6is ua||Dj aADq sasnDD |DJn4Du luojj 59403 q4D8Q S4jnpD 6unoA puo S4uaasa[opD 6uoujd sq4oap saij 40 400 auo A|uo JOj pa4uno30o sasnoa |Djh4du 'og^ L ul (^ ajn6iq) oBd sjdbA q p;p ;i uDq4 0403 q4oap jaqBiq d soq mou qaiqM dnojB aBo Ajuo aq4 S] sjqj_ -uasu soq 4| uaq4 aaujs 4nq 'Q961 IHun ll9i sjjnpD BunoA puD s4uaasappD p 34dj q4Dap aq_[ S4jnpy 6uno^ puD s^uaasapp^ p q4|D0|q aq| //6L-0D61 SJV3A C30313S 'S2:*:S G5;iNrs :Sjv = a rl Si S30V DOJ S31Vij m:V30 6ajn6ld 45 to 64 year-old adults The mortality rate of middle-aged adults has Fallen 27 percent since 1950, with the substantia! reduction in heart disease mortal ity being Icrgely responsible. As indicated in Figure 12, cancer deaths increased slightly during this period, due to a dramatic rise in lung cancer deaths. Mortality from other types of cancer fell approximately 10% over the past 30 years or so (19). Mortality from stroke, the third leading cause of death in this age group, declined 62% between 1950 and 1979. The death rote from cirrhosis of the liver doubled from 1 950 to the early 1970s, but has recently begun to decline (19). Accidents are the fourth leading cause of death in adults 45 to 64 years of age. Since 1975, more middleaged adults have died in motor vehicle accidents, while fewer have died in other types of accidents (19). The death rate for males in this age group is twice that of females, with the largest differential in heart disease deaths -- men are three times more likely to die of heart disease than are women (19). Overall, most middle-aged Americans report that their health is good. In a survey conducted in 1 979-80, only 6% said that they were unable to carry out usuai activities because of chronic illness, while 21% consid ered their health to be fair or poor (19). tality accounted for about one-half of this decrease in 22 23 SAL 000022514 the death rate. Deaths from cancer increased 13% during this time period (Figure 14). Cancers of the lung, colon, genital organs and breast (among Pqure 13: DEATH SATES FOR AGES 65 TEAKS AND OVER: UNITED STATES, SELECTED TEARS ! 500-1977 NOTE1977 fls:a are provisional: data lor all oinsr yea's a-'* final Selected years are 1900. 1925. i960. 1977 SOURCE: U.S. Dept, of Heolth, Educotion crnd Welfare, Public Health Service, Healthy People, 1979 Figure U: AGE-ADJUSTED DEATH RATES FOR PERSONS 65 TEARS OF AGE AND OVER ACCORDING TO LEADING CAUSES OF DEATH: iinitfDSTaTES. 1950-79 3.000 .2.000 Sl 300 Mean disease Cancer Stroke Influenza and pneumonia Diabetes meilitus ijo 90 -, &0 ^tS0 19&S J___ 1960 196b Year J______ JZl--l 1970 1&7S i960 NOTE Causes oi d*Jt* are assigned according ro me international Usi of Cajses 01 Death Because o( me decenruaj rewistons and c*a*gts ^ rules lor causeol-oeath seteci on. mere may oe some iac* qI comparaoHhty from one revision to the nexl The beginning odtes of tne revisions e'e 1949. 1956 idea, and 1979 SOURCE: U.S. Dept, of Health and Humon Services. Public Heolth Service, Notional Center lor Health SloMt'cs. Heolth United Scores.- 1982, 1982 24 women) accourjt for more than haif of all cancer deaths among the elderly (19). In 1979, as,in 1950, 75% of alt deaths among the elderly were dub to heart disease, concer and stroke. An additional 5% of deaths were the result of diabetes (19). Most older Americans retain their vigor and inde pendence, although 45% have some activity limitation caused by heartconditions, arthritis, hearing loss or visual impairmeit. The largest portion of chronic activ ity limitation sterhs from respiratory conditions, such as emphysema and chronic bronchitis (12). PREVENTING PREVENTABLE DEATHS While everyone has to die of something, we pre fer that it happens at a ripe old age. The best one can hope for is not tc escape death, but to prevent prema ture death. Publilc health programs should, therefore, focus on preventable causes of untimely death. The five leading causes of death -- heart disease, cancer, cerebrovascular disease, accidents and chronic obstructive pulmonary disease -- claimed the lives of nearly orle and a half million Americans in 1979 (22). Almost one-third of these deaths could have been prevented by modifying just three risk fac tors: smoking, hypertension and alcohol abuse. Four of the five leading causes of death are directly related to cigarette smoking. It is estimated that smoking is responsible for 30% of all cancer deaths, or 121,04)0 deaths in 1979 (24). Thirty percent of all heart disease fatalities, or 220,000 deaths in 1979, are also attributable to smoking (10). It is a major, but unquahtifiable risk factor for cerebrovascu lar disease and ^responsible for 85% of chronic bron chitis and emphysema deaths -- 42,000 deaths in 1979(10). (Infant and fetal mortality could also be substan tially reduced by decreased cigarette smoking. Smok ing is responsible for elevated rates of spontaneous abortion and stillbirth, and accounts for up to 14% of all premature birth in the United States (25).) It is obvious that if Americans really want to pre vent premature deaths and improve their health, giv ing up smoking is the place to start. As the World Health Organization has stoted, "The control of ciga rette smoking cou|d do more to improve health and prolong life in (developed) countries than any other single action in thd whole field of preventive medi cine" (12). Hypertension or high blood pressure, is responsi ble for aoDroxima elv 3% of heart disease deaths, or 25 SAL 000022515 22.000 deaths in 1979 (23). Thus, further improve ments in public awareness, detection and control of hypertension could significantly reduce cardiovascular disease mortality. Accidents are the leoding cause of death for Americans from the age of one through 38 (13). Any reduction in accidents would thus have a substantial impact on the rate of premature death in the U.S. Alcohol-related accidents are the leading cause of death of adolescents and young adults. Some 55% of motor vehicle fatalities (29,000 deaths in 1979) involve an intoxicated driver (26). Curtailing the use of alcoholic beverages by teen*ogers, and more cautious use by all age groups, would significantly diminish America's highway death toll. Cigarette smoking, alcohol abuse and hyperten sion are known to have contributed to more than 430.000 deaths in 1979. In contrast, there is little evi dence that most of the recently introduced chemicals in our food, air and water play a significant role in pre mature death. They may in fact, promote good health/ To prevent early death, the choices are clear. With limited resources, money should be allocated where it will do the most good. A comparison of the number of premature deaths known to be caused by allegedly "toxic agents" and the number of premature deaths known to result from the effects of cigarette smoking, alcohol and hypertension indicates that our resources are better spent on the latter. By keeping our priorities straight, we can have some control over the time and cause of death -- even if we all must succumb eventually. CONCLUSION One conclusion emerges from an appreciation of the health statistics presented here: America is not experiencing an epidemic of disease caused by mod ern technology and lifestyle. On the contrary, the health of Americans has never been better and con tinues to improve. The substantial increase in life expectancy, reduc tion in the death rate, and other improvements in health status which have occurred during this century indicate that the sum of all the health hazards to which Americans are exposed must be less than it was in the past. As Philip White, of the American Medical Associ ation, wrote: "Peril cannot be the cost of progress, for progress is in reality a reduction in peril" (27). 26 REFERENCES 1. American Cancer Society, 1983 Cancer Facts & Figures New York, 1982 2. Claybrook, J., Public Citizen, undated membership and fundraising appeal 3. Doll, R. and R. Peto, The Causes of Cancer, Oxford University Press, New York, 1981 4. Eisenbud, M., The environment, technology and health: A century of progress but o time of despair, American Journal ofMedicine 68:476, 1980 5. Evrard, J.R. and C. Evrard, How disgraceful are the facts about infant deaths in the United States? Today's Health 44(7): 72, 1966 6. Fingerhut, L.A., Wilson, R.W. andJ.J. Feldman, Health and disease in the United States, Annual Review of Public Health 1:1, 1980 7. Fries, J. F., Aging, naturol death and the compression of morbidity. New England Journal of Medicine 303: 130, 1980 8. Harper, A.E., The modern American food supply: Is it hazardous to our health? in The Modern American Food Supply: Is It Hazardous to Our Health?, American Council on Science and Health, 1 982 9. McGinnis, J.M., Recent health gains for adults. New England Journal ofMedicine 306:671, 1982 10. National Cancer Institute and National Heart, Lung and Blood Institute, Smoking and Health: A Program to Reduce the Risk of Disease in Smokers, Status Report, December 1978 11. Thomas L., Notes of a biology-watcher: The health care system, New England Journal ofMedicine 293: 1245 1975 12. U.S. Dept, of Health, Education and Welfare, Public Health Service, Healthy People, DHEW Pubn. No 79-55071, 1979 13. U.S. Dept, of Health and Human Services, Public Health Service, Promoting Health, Preventing Disease: Objectives for the Nation, 1980 14. U.S. Dept, of Health and Human Services, Public Health Service, Centers for Disease Control, Congenital Malformations Surveillance Report January-December 1980, 1982 1 5. U.S. Dept, of Health and Human Services, Public Health Service, Centers for Disease Control, Morbidity and Mortality Weekly Report 32: 309, 1983 16. U.S. Dept, of Health and Human Services, Public Health Service, Centers for Disease Control, Morbidity and Mortality Weekly Report 32: 389, 1 983 17. U.S. Dept, of Health and Human Services, Public Health Service, Centers for Disease Control, Morbidity and Mortality Weekly Report, Annual Summary: 1981 DHHSPubn. No. (CDC) 82-8241, 1982 18. U.S. Dept, of Health and Human Services, Public Health Service, National Center for Health Statistics, Americans Assess Their Health, Vital and Health Statis tics, Data from the National Health Survey Series 1 0 number 142, DHHS Pubn. No. (PHS) 83-1570, 1983 27 SAL 000022516 1 9. U.S. Dept, of Health and Human Services, Public Health Service, National Center for Health Statistics, Health United States: 1982, DHHS Pubn. No. (PHS) 83-1232, 1982 20. U.S. Dept, of Health end Human Services, Public Health Service, Office of Heolth Research, Statistics and Technology, National Center for Health Statistics, Health United States: 1980, DHHS Pubn. No. (PHS) 81-1232, 1980 21. U.S. Dept, of Health and Human Services, Public Health Service, Office of Health Research, Statistics and Technology, National Center for Health Statistics, Health United States: 1981, DHHS Pubn. No. (PHS) 82-1232, 1981 22. U.S. Dept, of Health and Human Services, Public Health Service, Office of Health Research, Statistics and Technology, National Center for Health Statistics, Advance Report of Final Mortality Statistics, 1 979, Monthly Vital Statistics Reports 31 (6), supplement, 1982 23. U.S. Dept, of Health and Human Services, Public Health Service, Office of Health Research, Statistics and Technology, National Center for Health Statistics, Advance Report of Final Mortality Statistics, 1 980, Monthly Vital Statistics Reports 32 (6), 1982 24. U.S. Dept, of Health and Human Services, Public Health Service, Office on Smoking and Health, The Health Consequences of Smoking: Cancer, DHHS Pubn, No. (PHS) 82-50179, 1982 25. U.S. Dept, of Health and Human Services, Public Health Service, Office on Smoking and Health, Heolth Consequences of Smoking for Women; A Report of the Surgeon General, 1980 26. U. S. Dept, of Transportation, Alcohol Involvement in Traffic Accidents: Recent Estimates from the Center for Statistics and Analysis, DOTHS806269, 1982 27. White R, Alternatives to peril. Food Product Develop ment, May 1976 American I1 ACouncil on Science and Health Yes, I will join ACSH! Annual Membership Rates: 13 BENEFACTOR: $5,000 INDIVIDUAL: $35 H PATRON: 3 SPON^DR: $3,000 (OVERSEAS). $1,000 Li STUDENT OR Li INSTITUTIONAL: $500 SR. CITIZEN: L ACSH NEWS & VIEWS SUBSCRIPTION ONLY: (ACSH NEWS S VIEWS OVERSEAS): $50* $15 $10 $16` `All c verseas subscriptions must be prepaid. II I wish tocontribute $ in addijion to membership dues. All contributions are tax-deductible as provided bylaw. Please make all checks payable to American Council c n Science and Health and mail to: 47 Maple Street, Summit, New Jersey 07901 PLEASE ArINT Name__ Address. City____ State___ Telephone Affiliation .Zip. ACSH members receive: ACSH Mews & Views, a bimonthly publication with scientific articles on health and safety: book reviews; guest editorials; and updates on current issues being researched by ACSH. Copies of latest ACSH reports, summaries, annual reports, and other materials. Information on national and local conferences and seminars. Please send membership information to: I PLEASE PRINT Name. Citv State Telephon e Affiliation. Zio 29 >AL 0C0022517 ^ezsr American Council on Science and Health Elizabeth M. Whelan, Sc.D.. M.P.H. Executive Director Richard A. Greenberg, Ph,D. Associate Director Lynne P. Middelveen, M.S. Assistant Director 1995 Broadway [near 6Qtn Street) New York. NY 10023 Telephone 212 362 7044 1050 17th Street. N.W Suite 900 Washinaton. OC 20036 Telephone: 202 659 8978 47 Maple Street Summit. NJ 07901 Telephone; 201 277 0024 Board of Directors Norman E. Borlaug, Ph.D. Director Wheat, Sarley and Tnticaie Researcn ana Production Programs International Cenier lor Maize and Wneat Improvement Lond'es Mexico F. J. Francia. Ph.D. Professor Deoanment ol Food Science and Nutrition University o! Massachusetts Amherst, Massachusetts Allrad E. Harper, Ph.D. Professor of Nutritional Sciences Professor ol Biochemistry University 01 Wisconsin Madison. Wisconsin Joseph F. Murphy. LL.B Department ol Insurance State ol New Jersey Board of Scientific Advisors Roslyn B, Altin-Slater, Ph.D. University otCalitorma. Los Angeles Lewis A. Sarness, M.D. University ol South Florida College of Medicine Stephen Barrett. M.D. Lehigh Valley Committee Against Health Fraud, inc. Norman E. Borlaug, Ph.D. International Center for Marze and Wheal Improvement Joseph F. BoRelleca, Ph.D. Medical College ol Virginia George A. Bray, M.D. University ol Southern California Medical Cenier Ernest J. Briskey, Ph.D. Oregon Stale University John P. Callan. M.D. Hartford. Connecticut Ernest E. Campaigne. Ph.D. Indiana University George Chrisiakis, M.D.. M.S., M.P.H. University of Miami School of Medicine F. M. Clydesdale. Ph.O. University of Massachusetts Julius M. Coon, M.D., Ph.D. Thomas Jefferson University T. J.Cunha, Ph.D. California State Polytechnic University Robert M, Devlin. Ph.D. Universilyol Massachusetls 30 Fredrick J. Stare, M.D., Ph.D. Prolessor of Nulfition. Emeritus Harvard Scnool of PuBHc Health Boston. Massachusetts Stephen S. Sternberg. M.D. Member. Sloan-Kettenng institute lor Cancer Research Attending Pathologist, Uncnllal New York NY Elizabeth M. Whelan, Sc.D., M.P.H. Executive Director American Council on Science and Healih New York. New York Janet 8. Douglass, M.S., R.N. University of Lowell, Massachusetls Merrii Eisenbud, Sc.D. New York University Medical Center J.S. Felton. M.D. University of California. Irvine Owen R. Fennema, Ph.O. University of Wisconsin DeanC. Fletcher, Ph.D Washington State University Ralph W. Fogleman. D.V.M. Upper Black Eddy. Pennsylvania F.J. Francis, Ph.D. University ot Massachusetts LaNelle E. Geddes. PM.0..R N. Purdue University Roger E. Gold. Ph.D. University of Nebraska Lincoln Alfred E. Harper,Ph.O. Universrtyoi Wisconsin William R. Havender, Ph.D. Berkeley. California Wayland J. Hayes, Jr., M.D.. PhD. Vanoerbilt University School of Medicine William E. Haaeltine. Ph.D. BuCle County.California Mosquito Abatement District Victor Herbert, M.D . J O. Bronx Veterans Administration Medical Cenier State University ot New York Margaret Hitchcock, Ph.D Yale Un.vers.ty William T. Jarvis. Ph.D. loma Linda University Paul E. Kifer. Ph.D. Oregon Slate University James R. Kirk, Ph.D. University ol Florida David Krltchevsky, Ph.D. The Wistar institute. Phiiadel; Manlred Kroger. Ph.O. Pennsyivan.a Slate University J. Clayburn LaForce. Ph.D, University of Cai|fornia. |_0S A les Lawrence E. Lamb, M.D. Communications. Inc , San Ar o Bernard Lown. M.D. Harvarc School ol Public Heal Howard O. Maccabee, Ph.D. Radialion Oncology Center Walnut Cree*. California D. Robert MacVicar. Ph.O. Oregon Stale University Roger p Maickel. Ph.O. Purdue University Henry G. Mantle. J.S.D. Emory University Charles D. May. M.D. Quechee. Vermont Kristen McNutt, Ph.O. Good Housekeeping Institute Joseph M, Miller, M.O. New Hampton. New Hampshi Dade W. Moeller. Ph.D. Harvard School ol Public Hea l Eric W. Mood. LL.O,, M.P.H. Yale Umversiiy J.E. Oldfield. Ph.D. Oregon Slate University Robert E. Olson, M.D., Ph.D University of Piltsburgh School of Medicine Grace L. OslehSO. Ph.D. Committee on Science and Te r ology U S. House ot Representative Frederick S. Philips, Ph.O. Memorial Sloan-Ketterlng Car Center Rita Ricardo-Campbell, Ph.C Hoover Institution. Stanfotd U rsity David B. Roll, Ph.D. University ol Utah David Peter Rose, M.D.. Ph.D. American -ea'tn Foundation Sheldonflovrh. D.D.S., M.S Universe, ~i Comsytvah.a Paul D. Saltman, Ph.D. University c( California. San D'eao Herbert P. Serett. Ph.D. Sarasota. Fip.-iaa Harry Schwartz. Ph.D. CbluniDia University Leroy L. Scnwartz. M.D. Tne Pnnceicn institute 'or Health Policy B. S. Schweigen. Ph.D. University ol California. Davis Sidney Shmdell. M.D., LL.B. Med'cai College ol Wisconsin Sarah Short. Ph.O.. Ed.O.. R.D Syracuse University A. J. Siedler, Ph.D. University ol Illinois Robert R. Spiizer, Ph.D. Milwaukee School ol Engineering Ronald T. Stanko. M.D. UnivaiSiTy 0t Pittsburgh School of Medicine Fredrick J. Stare. M.D.. Ph D. Harvard Sc nodi ol Public Healih JudithS. Stern, Sc.D. University ol California. Davis Stephen S. Sternberg, M.O. Memorial Sioan-KeUetirg Cancer Comer Stanley E. Wallen. Ph.D. University of Nebraska. Lincoln W. F.Wardowski.Ph.O. University Of Florida Esther M, Wender, M.D. Montefiore MedicalCenter Bronx. New York Philip L. White. Sc.D. American Medical Association Richard Witson. Ph.D. Harvard Unive'SHy Warren Wlnkelstein, Jr., M.D., M.P.H. Umversiiy ol California. Berkeley James Harvey Young, Ph.D. Emory University John A. Zapp, Jr., Ph.D. Kennett Square. Pennsylvania Juliette Zivic Public Service Company ol New Hampshire Policy Advisors S. John Byington. J.D. Pillsbury. Madison and Sutro John Diebold The Diebold Group, Incorpora Joseph F. Murphy, LL.B. Department of insurance State ol New jersey Julian L. Simon. Ph.D. University of Illinois at Urbana-Champaign. SAL 000022518 V) > C ^3 3 2 3 O) 3 5. -o o ~ 5" 2 ?2o 3I (oO * O3 -- ' ---- r--1 - - - ` ;--1 -- > - --r- .i' : : 1; !:;:;1 I ! i ' l, ; '1 ' ! i 1 I 1 '' : T : 'i1i ' 1 j ' ; | ! ;)!1 \ 51 tt, ti i, :i i1 ;! 1 : \i l i :; m . T; ;i . m /j 1 ". j1 i 11 :1 !i LTj' J* 1i ' 1 ! ! 1 I ., 11 ,i i !._L I - ! M--. . , \^ -J. ; i-r -- _L ! 11 --4- - MT 1-I--!h i:_L; _i_ _ _! _11 i -H-1 !i! 1| ! _ 11 !t ! 1nr , _ !j . F / ~rt 1. ji ! I: ' i1 TI i!_i! ini 11[ 1 .; I _1 1 ! ! _i !_ _ 1 _ i_ _ _ Li 11 1 ! 1 1 1 _1 !, i [ "j ! 1 11 if i i i_i i! " i 7"! ! " ill! i 1\ 1 .11 r' ^ : i; :! ,' ; \ _> ii. 1 ! i. ; , 'll , 'I ' . ; > | ' ! . 'i1 i( 'i i i :1 ,!!i:| : !| i! i !'j;;;, 1,i !!1'i !i 1l 3 j_ _ . ion ]_ _ 9} o9 oQ3j. `L11_--HL; iJi x<p 1r- - -r- 5 I _L 1 [ r L_ ` j-- i : 1_ _ _ - j : : ' i--i-- ! | i :1 i: : s1 SAL 000022519