Document xjybXDqnNEm0jzn9nVXZXOLRb

Losing the War Against Cancer Who's to Blame and What to do about it ' ' ` J -/ by Samuel S. Epstein In 1971, the U S Congress launched a War on Cancer. Sixteen y ea n and billions o f dollars later, the U S is still in the grips o f a cancer epidemic--and the num ber o f victim s grow s every year. M uch o f the money has been squandered on a fruitless search fo r cancer " c a r " . U tile or nothing has been one to prevent exposure to,carcinogenic chemicals in the environm ent--this * despite ample evidence that chemical pollution o f our air, water, and food is fa m a jo r cause o f canter. O n the contrary, governm ent, industry and a small coterie o f scientists have combined to stym ie efforts to introduce preventive measures, suck as strict pollution control standards. But cancer remains a preventable disease. It is up to citizens to push fo r action. Cancer b now a major killing diseaae In the Industrialbed world and Its rates arc sharply rising.* In contrast there have been major reductions In deaths from cardio vascular disease. stiQ the number one UDcr In the US. probably because of a recent decline In smoking and attention to d ietan d exercise. With over 900.000 new cases and 450,000 US deaths : last year, cancer has now reached epidemic proportions, wfeh an Incidence of.one In three and a mortality of o n e ! in four. Analysis of overall cancer rates, standardised for age, sex and ethnicity, has dem onstrated a steady in* crease In cancer rales since the 1990s. In recent years, the incidence rate has risen sharply, by som e2 percent a year, with mortality rates rising by 1 percent a year. Striking confirmation of these recent increases comes from estimates of the lifetime probability of getting cancer for people bom at different times. For white males bom In 1975 to 1965 for instance, the probability of developing cancer has risen from 30 to 36 per cent, whilst the probability of dying from cancer has risen from 19 to 23 per cent. Such increases in overall cancer rates are also reflected in the increasing Incidence of ,, cancers of the lung, b reast colon, prostate, testis, urinary bladder, kidney, and skin, and of malignant melanoma and lymphatic/hematopoietic malignancies. Including non-Kodgkln*s lymphoma.* Long cancer Is . responsible for about one-third o f the overall recent Increase In Incidence rates. It should be stressed that some 75 per cent of all cancer deaths occur In people over 55 years, and that recent increases are largely restricted to these ages. Static Cure Rates H ie overall cancer "cure rate", as measured by survival for over five years following diagnosis. Is cur rently 50 per cent for w hites but only 38 per cent for Sawmet S . v**rA* H D k M a t e rf OrMjW'wW m i ExwhmmmOi HHkiH0%SdmtfrHlkHmltk. UHmmry^WMk U'iirUCmhi. O w t*. AmSke The.M kka of C m e (Sierm Saab m i Amdim t DmUii t& m it* a lW afH *saJw a Wtmt 1 A n ita (Storm SaitaJL hr k m em qur H ike ef The Eeolbfto. TheC a U fli vq, 17, Afe 2. !M7 Marks. There Is no evidence of substantial Improve ments in treatm ent over the last few decades, during which the five year survival and ag e adjusted mortality rates for the major cancer kiHess (lung, breast and colon) and for moat other organs, have remained essentially unchanged* The only improvements have been for cancer of the cervix, and tor relatively rare cancers, such as testicular seminomas, H odgkin's disease and di3d* hood leukemias treated w ith radiation and/or chemo therapy. Apart from im mediate toxidty, such treatment, while effective can increase the subsequent risk of de veloping a second cancer by up to 100times. Increasing Carcinogenic Exposures Cancer Is an age-old and ubiquitous group of dis eases. Its recognised causes and influences arc muhifadorial and indude natural environm ental carcinogens (such as sflato rins and sunlight), lifestyle factors, genetic susceptibility, and snore 'recently Industrial chemicals. Apart from m odem fifestyle factors, particu larly smoking, increasing cancer rates reflect exposure to Industrial chemicals and ruivaw ay modem tech nologies whose explosive growth has dearly outpaced the ability of aodety to control them . In addition to pervasive changes In patterns of living and d ie t these poorly controlled technologies have Induced profound and poorly reversible environm ental degradation, and have resulted In progressive contamination of air. water, food and workplaces with toxic and carcinogenic chemicals, with resulting Involuntary exposures. With the dawn of th e petrochemical era In the early 1940s, by when technologies Including fractional dotillation of petroleum, catalytic and therm al cracking and molecular splicing became commercially established, the annual US production o f synthetic organic chemicals was about one billion pounds. By the 1950s, this had reached 30 billion pounds, and by the 1990s over 400 billion pounds annually. The overwhelming majority of these Industrial chemicals has never been adequately tested--If tested at all--for chronic toxic, carcinogenic, mutagenic and teratogenic effects, let 91 ok** Utf rYitIttgx'al rltiv ls oih n\w`\ it| Ihi* limited m iU M v iitduMru) diU b at M su sp x t. CVrupatinnal rtp m u rr Id imluMrl carcinogens lu cWifly c m c r^ d i i nujiif ri>k IjcIw Iiv cancer.' The National Institute (or Occupational Safely And Health (NIOSH) m im iica that x im r 10 million, workers are now exposed to II high volume rM d n ^ m i. Five lo 10-fotd iflo ris rs In cancer M l have been demon* rated in some occupation*. Also persuasive a ir Brkbh dala on cancer mortality by socio-economic class, largely defined by aip atlo n , which show that Ihe lowest class, particularly among males, has approximately twice the cancer mortality rate of Ihe highest class. Living near petrochemical and certain other industries In highly urbanised communities increases cancer risks, as dem onstrated by the clustering of excess cancer rates. High levels of tosic and carcinogenic chemicals are da* Hberatdy discharged by a wide range of industries into the air of surrounding communities. Fat1-oul from such toxic air pollutants b also an Important source of con tamination of surface waters, particularly th e Great Lakes* While there st3 are no regulatory requirements in the US (or reporting and monitoring these emissions, unpublished government estim a! Indicate that they are in excess of 3 billion pounds annually,1 Another example of the effects of run-away tech nology Is the hazardous waste crisis. The volume of hazardous w as! disposed of every year In the USA has risen from under 1 million tons b 1940 to wed over 300 million tons in the 1960s--more than 1 ton per US citizen per year. The industr i involved--fossil fueL metal m ining and processing, nuclear, and petro- chemicat--have tittered the entire land mass of the US with sem e 30,000 toxic waste landfills--30,000 of which are recognised as potentially hazardous--170,000 indus trial im poundm ents (ponds, pits and lagoons), 7,000 underground injection wells, not to mention some 2.5 million underground gasoline tanks, many o f which are leaking. Not surprisingly, an Increasing num ber of rural and urban communities have found themselves located on or near hazardous waste sites, o r downstream, dow n-gradient or dow n-w ind from such sties. Particularly alarming is growing evidence of contamin ation of ground water from hazardous waste sites, con tamination which p o s grave hazards for cen tu ri to come. Once contaminated, ground w aters are difficult, and sometan npossM e, to clean up. Environmental contamination with highly potent car cinogenic pcsticid has reached alarming and per vasive proportions. Apart from high level exposure of workers In manufacturing, formulating and applicating . industries, the contamination of ground and surface waters has become commonplace. Residues of etylenc, dibromide b evens of 1.000ppb in raw grains, cereals and d tru s fruits have been welt known to Industry and the Environmental Protection Agency (EPA) for as tong as ten years after its very high carcinogenicity was first dem onstrated; not u n til1964 however, did EPA develop a 30 ppb tolerance, which was rejected by the Common wealth of Massachusetts and the S ta in of New York and Florida, and replaced by much lower and less hazardous levels. While the exact num bers are un certain. it h probable that ten t of millions of ho rn Howsanoto dtofricris bring aaefcad Me drums for rispoeal as hazardous a u ia i Uttta la dona to NmN evarydap exposure to such chemicals, fa ot whtch hare bean tested tor their carcinogenic jfopafllfi nationwide are contaminated with varying levels of chlordanc/hcptachlor, pcsticid still registered by EPA or term ite treatment. It should be noted that, on the basis of extensive hearings some 14 years earlier, the Agency concluded that exposure to chtordane/ heptacWoc posed an "imm inent hazard*' due to cancer (b esid other chronic toxic effects) leading to a subse quent ban on their agricultural uses. Much cancer today-reflects events and exposures In th e 1950s and 60s. The production, use and disposal of synthetic organic and other Industrial carcinogens was then miniscule In terms of volume when compared to current levels, which win determine future cancer ra t for younger populations now exposed. There b every reason to anticipate that even today's high cancer ra t will be exceeded In coming decades. Concern has understandably focused on increasing cancer ra t but these substantially underestimate the extent and scope of the public health effects of environ mental pollutants. Only a small proportion of the tens of thousands of petrochemicals tit commerce, well under 500, are carcinogenic. However, many of these, together with other non-carcinogenic petrochemicals, can Induce other chronic toxic effects, including neurological res piratory, reproductive, hepatic and probably Immuno logical diseases, whose true causation b generally, not suspected let alone investigated. "industry has used various strategies to con t the pub!ic...and divert attention from their own responsibility for the cancer epidem ic/' . H ow In d u stry F ights R egulation ' Twentieth century Industry has aggressively pursued ehocl-lerm economic goats uncaring or unmindful of harm to workers, local communities and the environ ment. So far. industry has shifted responsibility for the damage it has caused onto society-at-large. Belated gov ernment efforts to control polluting industries have gen erally been neutralised by wethorganbed and weOBnanecd opposition. With the exception of special pur pose legislation for drugs, fopd additives and pesticides, there were no regulatory requirements for p retesting industrial chemicals unt3 the 1976 Toxic Substance Control A ct legislation which the industry had stalled for years, and which' b now honoured more In the breach than in the observance. Apart from the faSure to pre-test most chemicals, a bey characteristic of industry's anti-regulatory strategy has been the generation of self-serving and misleading data on toxicology and epidemiology, and on regutatory costs and cost-benefit analyses. The record of such urv.reliable and often fraudulent data b so extensive and well-documented as to justify the presum ption that much industry data must be treated as suspect until proven otherwise Attempts by the Carter Administration to develop comprehensive, 'generic* regulation of occupational car cinogens, later reversed by the Reagan Administration, were attacked by the Manufacturing Chemists Associ ation which created the American Industrial Health Council to organise opposition. Such reactions gener ally reflect a short-sighted preoccupation with perceived self-interest rather than with efficiency and economy. The virtual uniformity of industry opposition to regu lation b In marked contrast to the heterogeneity of the industries involved, both in terms of size and the diversity of their interests. Regulation has, In fad, gen erally resulted in substantial improvements in industrial efficiency and economy, particularly in Urge industries, by forcing development of technologies for recovery and recycling of valuable resources. A deplorable result of regulation, however, has been, and continues to be, the export of the restricted product or process to the so- called lesser developed countries.1 Apart from well-documented evidence on control a n d . manipulation of health and environmental information, industry has used various strategies to con th e public into complacency and divert attention from their own recklessness and responsibility for the cancer epidemic. Key among these b the 'btame-the-victim' theory of cancer causation, developed by industry scientists and consultants and a group of pro-industry academics, and tacitly supported by the 'cancer establishm ent'. T hb theory emphasises faulty lifestyle, smoking, and fatty diet, sun bathing or genetic susceptibility, as the major Dt? trcbxiu. Voi. t ?, N*. 2. IM? causes of preventable cancer, white IrtvUUsing the role of involuntary exposures to occupational and environ mental carcinogens. A nother misleading diversion b the claim that there b no evidence of recently Increasing cancer rales other than lung cancer, for which smoking b given the exclusive credit. While the rote of lifestyle b obviously im portant and cannot be Ignored, the srietv tific basb of th b theory b as unsound as it b selfserving. Certainty, smoking b a major, but not the only, cause of lung cancer. But a wealth of evidence deariy incriminatcs the additional rote of exposure to occu pational carcinogens and carcinogenic community air pollutants. Hence, som e 20 per cent of lung o n c ers occur in non-smokers; there have been major recent Increases in lung cancer rates in non-smokers; an In creasing percentage of lung cancer b of a histological type (adenocarcinom a) not usually associated w ith smoking; high hang cancer rates are found with certain occupational exposures independent of sm oking and excess lung cancer rates are found In communities where certain major industries re t located. The chemical Industry thus dearly uses tobacco as a smoke screen to divert attention from th e role of carcinogenic chemicals In Inducing lung cancer, besides other cancers. When it comes to diet, th e much touted role of high fat consumption, while dearly finked to heart disease, b based on tenuous and contradictory evidence with re gard to breast and colon cancers. The evidence certainly docs not justifythe wild daim s by lifestyle theorists that some 30 to 40 per cent of all cancers are due to (sully diet. Fortostance, a 1962 National Academy of Sciences report concluded that " . . . in the only human studies to which the total fibre consum ption was quantified, no association was found between total fibre consumption and colon cancer." Similariy, a targe scale 1967 study, based on the yating habits of nearly 90,000 nurses, con cluded that " --there b no association between dietary fat and breast cancer/* Another illustration of grossly misleading strategies relates to the identification of chemical carcinogens. When a particular chemical o r product b threatened with regulation on th e basb of animal carcinogenicity tests, the Industry Invariably challenges the significance of these tests, while routinely using negative test results as proof of safety. At th e same tim e Industry Insists on the need for long-term epidemiological Investigations to obtain definitive hum an evidence of csrdnogenidty. To test th b apparent reliance on direct hum an evidence, re searchers at Ml Stoat Hospital to New York compiled a list of some 100 chem icab accepted as carcinogenic on the basb of animal tests, but for which no epidemio logical Information b available, and sent th b fist to some 80 major chemical industries. Respondents were asked whether any of the listed carcinogens were to use and, if so, w hether epidemiological studies had been con ducted, w hether they were being conducted* or whether it was Intended to conduct them to the future, and If not, why not. The responses were revealing. The great majority of those Industries using particular car cinogens reptiedthat they had done no epidemiological studies, were not doing any, and d id n 't Intend to do any for various reasons. Includingalleged difficulty, 1mpracticality, expense, or because of Ihrir belief that these 93 Attirilo# N og stripped k w id io o li For y m n mo M m lfy rolifMO lo ctoowtodp# Ho cafttocgwUdty ol osbotloo,vm ootog to to as to Mppw# toerimtoaltog data. fvoo lodiy, V >J<i" asbestos to to *fcSot$r*sd v u , dtsplf# bstog o poloni carctoogsn. dicm kab could not possibly be carcinogenic lo humans. A,perfect catcb-22: knock the animal tests and Insist on hum an studies, but make sure that the human studies are never done. Industry positions are vigorously advocated by trade associations, such as the Chemical M anufacturers Association, public relations firms, such as H S and Knowlton, front organisations, such as th e American Council on Science and Health (the contributions of whose director* Whelan, have been aptly characterised as "voodoo sdence'Ti and lay w riters such as Efron (who charges that the American scientific community has been terrorised into submission by environm ental "apocalyptic"). Disturbingly, another m ajor source of support for anti-regulatory strategies Is a stable of academic consultants who advance the industry pos ition In arenas including the scientific literature, federal advisory committees, and regulatory and congressional hearings.* -<Government and the Cancer Epidemic Presidents play a powerful role In setting national public health priorities, not unnaturally reflecting their ' own political agendas. Reagan, however, is unique in having run for office on an ideological anti-regulatory platform, and in having then systematically used hto office to implement this ideology, often in contravention ' to the spirit and letter of the law. Reagan has thus neutralised legislative mandates on controls of toxic and carcinogenic exposure by direct frontal assaults on regu latory agencies.' Strategies employed include: staffing senior positions with unqualified, ideologically selected - 94 staff hostile to their Agency mandates; budget cutting; insisting on formal cost-benefit analyses which focus un industry costs with little (or biased) consideration of the costs of failing to regulate and which effectively stall the regulatory process; illegal behind closed doors meet ings with Industry; and making regulation dependent on the Office of Management and Budget with Its sub servience to the White House. An example b tfie While House decision to block the S U million 1904 request by the National Institute for Occupational Safety and Health (NtOSH) to notify some 200,000 workers of risks from previously undis closed exposure to workplace carcinogens, as identified in some 60* government studies, In order to finable medical follow-up and early diagnosis o f cancer. The reason for this refusal of modest funding teem s to have been a desire to shield corporations from possible legal claims.* Such a track record Justifies the conclusions of a 1984 Congressional Study Croup report that "efforts to protect public health and the environment from the dangers of toxic pollution have ground to a standstill under the Reagan Administration . . . (which was charged with being) a public health hazard." The US Congress has become sensitive to public health and environmental concerns, as exemplified in a plethora of legislation in recent decades.* Such legis lation has evolved fragm entary, reflecting particular interests and priorities. New laws have focused on Indi vidual environmental media--air, water, food or the workplace--or on individual classes of products or con taminants, such as pesticides or air pollutants, w ithjitile or no. consideration of needs for more comprehensive i-v. 1I1 0 and integrated approaches. Furthermore, the legislative language has traditionally been ambiguous, thus allow ing maximal regulatory discretion to bureaucracies V' `.which in, some instances, have subsequently become closely associated w ith or even "captured** by the regulated Industries. A noteworthy exception is the 1958 Delaney Amendment to the Federal Food Drug . and Cosmetic Act, with its absolute prohibition against the deliberate Introduction of any level of carcinogen Into the food supply. Even sow the Reagan FDA b redefining the Delaney Amendment to allow carcinogenic food additives st levels alleged to be devoid of significant risk. Congress has also tended to abdicate dedsaon-makihg to scientific authority (or perceived authority), rather than questioning Us basis In the open politics! arena. Of particular importance was p assage of the 1971 Cancer Act In response to orchestrated pressures from the "cancer establishment**, the National Cancer Institute (NCI), American Cancer Society (ACS), and clinicians aggressively pushing chemotherapy as a primary cancer , treatment. The cancer establishment misled Congress into the unfounded and simplistic view that the cure for > cancer was Just a ro u n d ' the com er, provided that Congress made available massive funding for cancer treatment research. The Act did Just this, while failing to emphasise needs for cancer prevention, and also gave the N O virtual autonomy from, the parent National Institutes of Health, whOc establishing a direct chain of command between the NCI and the White House. Some 16 yean and billions of dollars later. Congress still has not yet appreciated that the poorly-informed special interests of the cancer establishment have minimised the importance of critically needed cancer prevention efforts, and have singularly failed to support such efforts. Nor has Congress appreciated the long overdue need for an investigation Into the conduct and priorities of the N O . Given the heterogeneity of congressional interests, the complexity of the problem Involved, the heavy lobbying by Industry, the indifference of the general scientific community and the well orchestrated pressures of the cancer establishment, it is not surpris ing that Congress has still to recognise that we are losing the war against cancer. = Until recently, state governments have largely deferred to federal authority, exercising relatively minor roles In cancer prevention. Reagan's federal deregulatory efforts have begun to reverse this relation ship. Regulatory actions against carcinogens are now emerging at the state level, such as the banning of chtordane/heptachlor and aldrin/dieidrin for termite treatment by M assachusetts and New York, the banning of damlnozide (Alar) for apple ripening and tough restrictions on ethylene bromide food tolerances by Massachusetts, and the Introduction of Informative oc cupational labeling taws by various states, such as the "right-to-know" workplace legislation of New Jersey. In some cases, such state Initiatives have evoked federal preemption by restricted regulations--such as the 1983 Hazard Communication S tandard/of the - Occupational Safety and Health Administration-- despite Reagan's avowed commitment to getting big government off the backs of the people, In February T>ifrv.ifwa, v,4 7. Nm. 2. 1*47 , .. 1987, a coalition of labour and citizen organisations asked the US Court of Appeals to enforce Its 18 monthold order directing OSHA to expand coverage of its communication standard from manufacturing to all workers. In an apparent about face turn, the Chemical Manufacturers Association Is supporting the expanrion In conformity with regulations developed for various states. The Cancer Establishment: Standing In the Way of Prevention The cancer establishm ent stM continues to mislead the public and Congress Into believing that "w e are winning the w ar against cancer*', with "victory" possible only given more time and money. The N O and ACS also insist that there have been major advances in treatment and cure of cancer, and that there has been no increase bi cancer rates (with the exception of lung cancer which b exclusively attributed to smoking). Yet, the facts show ju st the contrary. The cancer establishm ent periodically beats the drum to announce the latest "cancer cure", and dramatic "breakthrough". These announcements reflect optim ism and wishful thinking, rather than reality. The ex travagant and counterproductive daim s for Interferon as the magic cancer bullet of the late 1970b have been followed by the unpubUdsed recognition of its limited role bi caAcer treatm ent.1* The b le st N O "break through" daim s for biterieukin-2 as a cancer cure are grossly inflated and rest on questionable data. These claims fail to reflect the devastating toxicity and lethality of th b drug, and gloss over the high treatment costs, which can run into six figures. Equally questionable are daim s by the NCI and ACS that overall cancer survival rates have improved dramatieaQy'oyer recent years. These daim s, based on "rubber num bers" according to one prominent critic, Ignore factors such as "lead-tim e bias", earlier diag nosis of cancer resulting in apparently prolonged sur vival even In the absence of any treatm ent and the "ovcr-dU gnosb" of essentially benign tum ours, par ticularly those of th e prostate, breast and thyroid, as malignant. Recently the director of the N O , DeVha, resorted to blaming community doctors for using In adequate doses of chem otherapy drugs as the "real" reason why cancer cure rates are no better than they are. The N O m isrepresentations are welt reflected bi budgetary priorities which are largely and dis proportionately directed to cancer treatm ent research-- to the neglect of cancer prevention. Even the very modest funding on cancer prevention Is largely directed to endorsing industry's "bbm e-the-victim " concept of cancer causation. Thus, the f*G exaggerates the role of tobacco for a wide range of.other cancers besides lung cancer, and treats as fact the slim and contradictory evidence relating diet to colon, breast, and othT cancers. Apparently still oblivious lo mounting criticisms, the N G continues vigorously to propagate these misrep resentations. A 1986 N G document on cancer control objectives, the executive summary of which falls to even mention environmental and occupational raposutes In carcinogens and focuses on diet and tobacco as the 95 * major causes of cancer, rashly promises Ovat annual cancer mortality rales could be reduced by 50 per cent by the year 2000. M ore disturbing th an Indifference to cancer prevention b evidence unco*red in September 1982 by Congressman Dave Obey that the NCI has pressured the International Agency for Research on Cancer (1ARC) funded bi part by the NCI, to dow nplay the carcinogen icity of benzene and formaldehyde In 1ARC mono graphs w hkh review and rank the cardnogenk lty data f: blacks primarily on their diet and smokin^hiabits, ' which diverts attention from the fact that blacks work In the dirtiest, most hazardous fobs, and Uve in the most polluted communities. A few days after the press conference, ACS announced a **new set of policies**, passing resolutions for the Improved regulation of such chemicals as asbestos and benzene, and the cleaning up of toxic waste sites. However, there has been no evidence of any real change of heart In the ACS, since then. ' on industrial and other chemicals. Such evidence b noteworthy since contrary to the scientific literature The Lifestyle Academics and its own exptidt guidelines, 1ARC has also dow n graded the carcinogenicity of other carcinogenic industrial chemicals, such as the pesticides aldrinf dieldrin and chferdane/heptecN or, and the solvents trichloroethylene and perchJocoethylene.M Over the lari decade, consistent with its low priorities for cancer prevention, the NCI has played Utile or no " role in providing the data base in support of critical = federal or state legislation and regulation on cancer prevention. Examples where N O scientific input could have been reasonably expected indude attem pts to prevent the exposure of much of the US population to carcinogenic pesticides, such as ethylene dibrom ide V residues bi food o r chlordane/heptachlor in th e sir of a high percentage of the many million hom es healed for termites, and also exposure to industrial discharges of carcinogenic air p o llu tan ts o r d rin k in g w ater contam inants. Following nearly a decade of fruitless discussions with The lifestyle academics are a group of conservative scientists including Sir Richard Dotl, the Warden and Director of the industry-financed Green College, Oxford,0 his protg R. Peto, a statistician also from Oxford, and more recently Bruce Ames, a California geneticist. The purist pretensions of "th e Ufestyters*' for critical objectivity are only exceeded by their apparent indifference to or refection of a steadUy accumulating body of information on the permeation of the environ ment and workplace with industrial carcinogens, and the Impact of such involuntary exposures on human cancer. ' Consciously or subconscious!y, these academics have become the mouthpiece for industry interests, urging regulatory inaction and public complacency. Among the more noteworthy contributions of these academics b a series of publications claiming that smoking and fatty diet are each responsible for30-40 percent of aDcancers; that sunlight, drugs and personal susceptibility account the ACS, at a February 7, 1984 press conference, a national coatitioh of major public interest and labour groups, beaded by the Centre for Science in the Public Interest (and myself), and supported by some 24 independent scientists, charged that the ACS " b doing virtually nothing to help reduce th e public exposure to cancer causing chem icals.. . Despite its promises to the public to oo everything to 'w fpeout for another 10 per c e n t leaving only a few per cent unaccounted for which, jurt for want of any other better reason, was then ascribed to occupation. According to the li/estylers, ih b then proves that occupation b an unimportant cause of cancer, which really docs not warrant much regulatory concern. Apart from circulatory referencing each other as 4. cancer in your lifetime*, th e AG failed to make Its voice heard In Congress and the regulatory arena, authority for these wild guesses, the Hfestylen have never attem pted to develop any estimates of how many where it could be a powerful influence to help reduce public exposure to carcinogens.** More specific criticisms Included the following: ACS fails to su p p o rt and at lim es has been . <hostile to, critical legislation that seeks to reduce or eliminate exposure to environm ental and occu- workers are exposed to defined levels of specific carcinogens. W ithout such estimates there b no way of attempting to determine just how much cancer b due to occupational exposure. The lifestyle theory was further advocated In a 1961 ' ` national carcinogens. For example, ACS refuses report dealing with causes of cancer In the USA by DoU to (pin a coalition of m ajor organisations. In and Peto where they denied evidence of increasing cluding the March of Dimes, the American Heart Association, and the American Lung Association, to support th e Clean Air A ct ACS h as rejected requests from Congressional subcom m ittees, unions, and environm ental organisations to ' cancer rates other than^fdr lung cancer, which was largely ascribed to to&acco w ithout adequate con sideration of the importance of community and oc cupational exposure to carcinogens.0. To tesch their support their efforts to ban or regulate a wide mbleading conclusions on static cancer rates. Dolt and v range of occupational and environm ental carcinogens. Giant corporations, which profit handsomely while they pollute the air, w ater and Peto excluded from analysis people over the age of 65 and blacks,, those groups w ith th e highest and food w hh cancer causing chemicals, must be increasing cancer mortality rates. Not content with such ' greatly comforted by the AC5*s silence. manipulation, they claimed that occupation was only ACS*s record on supporting efforts to ban responsible for some 4 per cent of'atl cancers, without carcinogens b dismal. O ften ACS' statem ents apparent consideration o)[ a wide range of recent studies are expressly or implicitly hostile to regulation. ACS's approach to cancer prevention largely ' reflects a ''blame the victim** philosophy, which em pasbes faulty lifestyles, rather than workplace dealing w ith th e carcin o g en ic''effects of su ch exposures.MTWs wQd 4 per cent guess was matched by "guestim ates" that diet'was determinant In some 35 per or environmental carcinogens. For Instance, ACS cent of all cancers. To trivialbe the significance of animal blames the higher incidence of cancer among carcinogenicity data on Industrial chemicals. Doll and f 9ft *f op bond by New York, the Environmenti Quality Bond to replacing the NCI's director, De Vita, who, in spite of . ct of 1986; end passage of Proposition 65, the Safe , h b contrary protestations, has been indifferent If not ^Drinking Water and Toxic Enforcement Act of 196$, by hostile to cancer prevention efforts and who has played . . California. | 'V major role in perpetrating the myth that we are win- ^ Proposition 65, masterminded by the Siena Club and * ning the war against cancer, senior N O staff should be ' the Environmental Defense Fund and supported fay a restructured and boosted by professionals competent in cootition of Californian public Interest citizen and labour ' environmental and occupational canccr ahd committed groups, is a sophisticated referendum which imposes 1! to cancer prevention. The National Ggnccr Advisory ;tough financial penalties on industries knowingly dis . Board should be reconstituted with a balanced mix of charging carcinogens into the drinking, w ater supplies, Independent cancer prevention professionals, repre and which makes mandatory the full public:disclosure of such discharges by Industry and alale officials. A vocal opponent of Proposition 65 was Bruce Ames, who sen tativ es of public Interest and labour organisations 'and concerned citizens, and should be subject to dose Congressional scrutiny. Such scrutiny should ensure nonetheless failed to impress the California public with that the institutional resources are largely directed to his lifestyle advocacy and h b trivializing the significance cancer prevention, that grants and contracts reflect th b of carcinogens in drinking water. Potential opposition priority and that N O staff play a key role In providing by the petrochemical industry was anticipated and r thc supporting scientific basb for legislative and regumuted by the earmarking of some 50 per cent of . latory cancer prevention efforts at the national and state revenues from fines for the stair superfund budget. levels. However, Governor Duekmejian, responsive to special ' Cancer b essentially a preventable disease. O ven VJ interest lobbying,. Ijas?recently ncutralbejdThe scope of -high national priority, th b goal will be achieved. the new legislation by restricting its scope only to ^epidemiologically confirmed carcinogens. This re --- -- - stric tio n U now tinder legal challenge. Irrespective of the outcome of this challenge. Proposition.`,65. has ^excited national interest and is being used as a model for similar regional Initiatives, such as the 1967 Saf Drink ing.Water Act of New York which b currently being drafted; ''Ailed fcayneto presentation* at S r National Srirty and Health C a d tm n af the Imin uHn u t Asaoctatien 1 M ackM us, Wathfa*** DC March % t 7 . fee Rkh National fo tirid r forum ef I k N ^ M C n U on A{Sm I S t M a w d M d d n W nM npon. DC U k d itl, I1S7. and fee C td w n w an Q ob d D ptfa^M f* and EnvVsnmenlGM*. W ad i at the EmS (Sehaba# AlamjL Penang, Malaysia, AprS S H P . ^ ^ y y j^ n g early Congressional priorities should be en.-Actment of comprehertsiv* whitecollar crime legislation. This would impose tough sanctions on individuai Copyright. t1P, SmmnI S. Eprtrin. executives, managers and professionals of industries found guilty of wUful "non-disclosure" of Information on hazards to workers, tqcaicom m unities and the nation. White collar crime^legtslation should also be extended to US and multinational corporations which export carcinogenic products processes which have been banned or regulated in the US to "lesser devel oped countries", -especially 'in the absence of fuU db> clasurcof* hazards directed to ultimate users and con sumers. Attention should also be directed^developing comprehensive new "cradle-to-lhe-grave" legislation as the basis for regulating toxic and carcinogenic chemicals. Such legislation can be designed to comple ment regulation by the judicious application of marketplaceprcSsures, inlheYorrn of financial Incentives and disincentives designed to wean industry away from un safe practices, and to ensure that responsible industry is not penalised or subjected to unfair competition. At present, other than the prospect of toxic tort litigation, there are virtually no incentives for industry to develop safer rvew ,LegistatIon is needed to develop federriynding for reiearch and develop ment into such benign technologies and to ensure that they are closely coordinated with environmental.;;' energy and resource policies. A critical legislative priority is (he amendment of the: NatiriaCancer Act to give the highest possible priority to cancer prevention; to redress the historical imbalance existing in the NCI between cancer prevention and re search on diagnosis and treatment; and also to insulate the NCI from direct Presidential influence. In addition N otes t.'fu e l.fa y ay I y w iiid M contrast. >mortality fio AIDS (MWWTVBWWy ffTVVtUJNcVBMf| PlfWyl fNgrVyIWIP* h | vH nat catartrphit b relatively tew. About fu n , 'feme than had ahead fatal bave Wen is ported dace tSSI hew thrdtteM r waa fr* detects* iliH w d f , 0 la rstfrnttrd that 2*1 He w m many Americana u r ta Ir e i advanced i) e y taw i of the A D S n U d compir* which often pwy i i i u le fa i Mown AIDS. Kip S y Incfoaelng n w etai I caae*. totaling aonw 270.000, arr p n y c x ity I tti. 1 ll shout* however, hr nctrd Our (h m here bee* w k iiin lU d a c iu m In ram lor tiomach and crrvh, and Im to, lor rectal cancer. .-s 3. In W t, a Hue. ribbon mww w x it tom mission (under the a fievt d the Own Health Education and Welfare (HEW) Sec- m w y Cattano) estimated, on the t u b ef Ow only avaSifele n parure data, IKX up lo 31 per cent of a l cancen to tiftming decade* would reflect peel and continuing n p o tu m to )uil >t high ohim occupational carcinogens. In spite of the recognised M m In u of three estimates, both In the Abaction of over estimating npoaurt to certain of the named curinot ene, par- tiritUrty aabertoa, and a ladino le tefleri a wide tango of other S t mow aignificant nnosuros, ttwk magnitude was avrf confirmed by industry imiwlUWx S lllo n rs and bf t% University of T ru e School otPbU k Heakh, In a 'confidentlti"'report cowunttoned ty<rthe America^ Industrial Health Council . 4. The Enotronmenial ftf r ectjtto Agency feat diverted attereion aay from Us feduce so regubWsiicVloOc rm isibn*. akhough so authoriaed under Sec. ,112 of.the W 0 CWan Air Act, by at tempting le ihik mpunsabttty lo local and state agende* and by a barrage ef pourty supfHirteble rialma that Indour alr poOutfcn. ; hom poSutant sunt as cigarette wmAIng. radon arid pesticides.1*34 is a muro Important.irgulatory target than teak air etniaskma. In ifdeoftM a near rsrivtive emphasis on Indoor air polutkin.n*A sZ refuses to ban the continued use cd such carcinogenic pesti- ( d n as CNUrdanr anJ AUrin, huh used rrtenshrrfy b r ilm n lir liiwute uoatment. I Inhwmatinn on such p v w bvmg systematised by Consumer Intrepid, a pmgtjmnu* *d the Interrufamal Organnathm id fm - Unton OOCU) U H tn Ptnang, M iliy ik M di p m (h protection le t the rowuww fro < w > t u i product*. The narik to antj In this w i art consumer, eneironmsnial, > u m M f o ih ir dtfam p e w f ca ia i w j about w n m te i^ toad* In K uH dew substance* t n l f r i f r t |)d frl dbaemlmtlon :ef auch hazard* the multinational carperattone involved me afao repcnafrlr lor the b W US Jobe end iM r H icw n iil ky cheap "geptndifcla" foreign labour. 4. These consultants IndudKMacMihGn, a Harvard cptdemfobigtol who h at citercd h it contracted rtu d k t with industry before sub,d ew far puMitttiont Dtmoupouioa. e pathcloghtatthe fort University Medkri C e n tr e d daLw Out burgh (M wnk^!School ef Medicine dm lue w tiM Out 1C id n o iie k In k da* not M u n c ure In anfrnafatHeyes. n C w C r far P m mw ChhwI (CDQ end Vamfarb lt Unfaevrily School of Metficfrfa. A g te (v ^w ttd y m record ee ejecting the hwnen d p i el anfrnal cmdnogenkhy date on orgamchlorine peeOridrc end Harttec^ a totonlnrirt fro Unirovriry el A ru m , M ufcd School, who In MOO M A d ee e iw in o e it witn* Out rodents are "goad p rtd k ten ef human cancer risk**, and whetaa en imheeajy n p rrt. Iie lf r l fuel the ocfcefrt In M S. 7. Such auocteeee of the Reagan Adminwntioa at the regulatory In u to g , contneito ke faflote to th e any ting of pufc&c haihh and regulations, For Instance, a M S report ky thr Office 1 Sdtnce and Technology Pokey e l the-Whhe Howe cfaeriy affirmed each critical Im rt the value ef animal cmcino- gtnicky data to crtrapolitfng to human rhk. and the Inabdfry to Mt Mw r level or thm h ohto" far w w w w m carrin o f n*. f. O r Fibrumy 3fa 1967, herrlnga were arid before thr labour and H enun l i n n n i Cemmfrtrr a a e M iponocnd by Senator U rtaenkeu* te require tW Department of Heekh and Hmnan Service to notify part cr prsarnl vrortcr known to be rt thk ad eencer and other o c n p tin u l dbcaae* To the annoyance 1 Ki PubScen Cenwdnee member* MOSH officiate aupported the MU Mcb wee eesoeed ky t ijndnVntirm spofcermcn who Seemed that k vrouU depfitaietairtbig effact and generate "loo much firigatioa". Thr arnior dtoaentiog officials rm rvvd a N k sequent " f r n e f r | dawn** h e n the Administration. Howw r, enenperted su pport k r f tr M m March 27, W c a n r h c n tW XCO aodii American Dn tio nke Association. a trade gim p, fro AML the Digital E p p o n t C oloration, and fro the Genend Efactric Company. 9. Cengreae, homeear, hatyrttoroccgntoi rite need to comldre ret practlcaa fie the orvaperthpe el white cokarohne. Whhe cedar crime Itrdbdmn ion klume heretofore keen rerfuewuly to rcorw icaky motWated afou l with economic com n and from vtolatfan* Effort* such as the 1979 M l M b ky Ceng. )e ln Cdnyere 0i.IL 9973 k SOL to ertm d inch legislation to economicaly motfaaird crimes wkh p iMe heekh or rm fronm tnld conerquencv* reswiring from wdftd supperaeton or "now diariaaurt" el rU e from f iu n f r u product end ptorteae* here not yet keen aucwmhd. Thia lith e erne In apke or the fed dut theconerqumcea el auch crime may be owmured In countWmencer I r a k 10. lnfrrfrw a la particularly effective. If hot often curative, fear two rare nroplnama hairy erfl Im lirw a and aw wili laryngeal 11. Apart from the noted n cr p iw n the lARC monographs art n ip t end w il yUreutncd compendii of date on the chronic touchy, carcinogenicity end use* oI a wide range of industrial 'end ether chemicals, 12. According te a faundmg M ow. Hermann, Crven C rfkgr a n m fahthtd In 1979 ee a "special pofrd of m try lor industrial in tem ti wishing to coRaberrte wkh oarvrrefry departments in mrUciw"*. , 12. TVs atudy w u sponsored ky the Office of Technology Aaaraa m t , v m t contract ofAcrr Gough w apparently unable to find any U$ reports with knowledge of cancer to Ihe UU and rim ed khtiah Wrrtyie adrorate ter the protect. (Gough la abo tuberquertly on record in a kook on Agent Orange re Aatniiting evidence en the lu u r f r ef dioain, inriudfag m eeting rvidmee of He arrirwgrnio ty heard on ertmawe anwnal data. Giwgh rremtiy Irfr OTA far a portion in a chrmical tndurtry conaufring Nrm.) Apparmrly reaponanw to rrilinama uf a draff erp u t. The Offke'of Trrhnofagy A u n m n t dreidrd agamai fra puMirathm, 14. Even If cmiy t per cent td anreta in the gm rral p ip b la n are rcruputisnil'in origin, thia whflwt Ihut w ru p au n a irapnonNf k aw ir 30 prv em t id a l ranerr in n p u n l w rrkm . 15. The IU * T component oI Agent Orange w it contaminated with a high cencrntranone aI ^ W r t i d m o f f r t M t d b i h which, . 9 accordfr>g 1 the Cardnog tn Amrt imenf Croup o l ETA, la the moat fo u n t cardnogm k turn ever evaluated, keing some 7*fald . order ef i gnkudr mere carcinogenic than the potent can CMOfW--r ^ .J-.i a * U . A m fade 1 t e n d Ma logic by drifting that farce are cardnm w it, although they are * rich aource of bacterial mutagmal Moreover, aeeoming that Aim i* emhiaionary itn p tin lt on dietary cardnogma hae sdtnlifir vakdfry. the critical iaaue la not what carcinogana are **natural"* and what are industrial ( W at la an am ple of a cardnogtn belonging lo both cate* tortcak kut what r f o tu m are areventablr or at k art reduce* able. 17. Ubeval crganltrtlona and progressive labour group, through ef fective veaeancK writing, duvet n t l and public advrrtfalng, are now chalm gbigthe abdkyof burin am ta larm lale thenatfanri agenda and shape the debate on haak social Im m , such aa v w itf i i |h k taaaden and amdronmental concern^ and an farrlgn yokey. Such crxiniarriona Include the Centre for National Fahey, Ckfama far Taa )uatke. The Democracy Project headed ky Mark Grrerk The Economic Fahey Institute headed by Jeff f a n , and the Coencf far Economic frfaritire. Bibliography This kdfujtmyfry a arlacffreand fa g w f Je p m fr kty i^ jb w o te oaetrr pwerurim and ne frapafairt. . Ae.rraC " ta nking Fwakfa Carcinogrnic Haurda**. Stinacr 22fe 271*2Mt M 7. N. A. A iM n id A Centre far M kyAkemathre of the MTT, Im rfk af b u m m a d , fiaafrk mad Sanity Acyiilafian, Krport to the US Senate Coaamittae on CuMiwmrntal Affair^ 9Cth Con erraa. March 2S. MO. N. A. Ashford mid C, C. Caldart, "The Right to Know; Took Infor mation Transfer ba the Workplace". Am. b e f i k Hlfk. k X3-t01, 1*95. O. Awiaon. "The Health Effects of Phmoey Add Herbiddr** In Rarruf Airmen fa Onre/uriawafHaalrk. Ed. |, M. Harrington, No. 2. Src. S, 2 S 2 k k Q w iid LMngrton. New York. IS04. (See abo O. A n e o g Rrfeutlrt r/tfrr ffart Rrywt m Csaw ly the Aayaf Cwa fa m au far Umand f f a ti r^OWmitaf A ja rt ee A n lfriw Anam avf fa Vfrtam, Linkping Unfaerafry. Swedctv January 21. 1994.) ). C. M u and L M. Smfrb, "Fm gm a Against Cancrrf" Nrw Cay. j, M ri j l i 1239-1232. 1919. 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Dnfr and R, Prto, `The Cauaroof Cancer: Quantitative Ealfrnatrsnf AvrilaNe (trika ef Cancer in The United States Today". J. Nat. Gmrrr lU. M I1*M.V. 1991. . /. Elder, r td (Creai U Im B ain Working Group). T u k Air h/bthm m ter C m i tate fas.* A Ce0 fmeActio*, M udi 1W . Environmental Proaction Agency, H ad* A u a to n f O m w nt M k U m tfW M n u if D e n EPA, September, IMS. X S. Epstein, "FbShned Date**. TWSm k m Ifc IM I. It7X S. S. Epstein, 7ke M irio ^ C iw r, Sierra Club Book. San francko* IfTB. Revised and Expended Edition. Anchor PreasfDouMedty, New York, NT*. & 5i Epetein and ). Swam . " F d b d ti cl LdeUyte Cancer Thacrtsa.** Natwe2Bf: 127-1301 IMI. & & Epnrirv "Coei-Beiwfii Anatysla: Inapieed by RmIomI Economic or a Aotadiomal Philosophy , TheAannu Jaunssf, p iM 7 , Spring im . S. S. Epetein. L L Brown and C Pope. limar4am Water ae d rovtre. Sierra O ub Book, San Frandscu. t9 H S, S. Epstein and). Sw am . *HbutUl to Anus on Cancer and Diet**. Scineor 224: *04*1. 1M4. (This letter wao co dgned by tom e 2D nationally rsoogrised authorities in the fislda of public toafcX and te rk o ra m u l and occupational crerinogcneth ) & & Epetein and J. Steam , Trdunmy ia Sample# ofa Zne T d w w tjb EDI. Pubttc Hearing on final Regniartonaof EPB. Mesaarhaiaete* M udi If, 1M4. N. Freudenbcrg, "O ticrn Action lor Environmental Health: Report on a Survey of Comasuolty Organictriorne**, Aae./. Addir fin ite 74; 44444X 1964. friends of the Earth, Natural Reaourree Deli nca CounrC The W iden neat Sodate, Sim a Oubw National Andubon Sodrty, Environ mantel Defence Fung, Environmental Policy Centro. Environ* mental A dfan D cfrndm of WBdfife. and Sciar Lobby, lal irtm dr TheCateAjcamrt tee Ra^ mEiMSMumertri f areel. Washington. DC M m h ltt, General Accounting Office, Rapo* on Aegm a im Canore T in te n e A fter adSemmL HQO-IMZ, Apetf IX IMC7. J. Could, Quality mflift m Amn k m w i i i m b a b : Eroefe tiA ffhm ut, Teak Warlr. and C e u r iUerta/ity ee ttgidemtU L if Gedr Amu* Cbuncf of Economic Priorities, Westview Presa. Boulder, London, TO*. H G ram Ed. T k ly lw in d Rmdrr, P flp in Presa, New York, MBS. W. F, Hunt. Tal, Office of Ah and Radiation. Em itonmr n ltl A otoc bon Agency, UHrnmt Gmcrr k id rao r JUtr* for Sdarimi Tarir Air PaOttante Irony Aaddite Ar Paflttun Otte, EPA*Aped 2X IMS. }. K Ives, Ed. n r Eiparf mf H m te: T fe u te in d Cmjrnt^m m and Zmwimmtmhi Cornimi been. Routledjge and Kagan Paul Boeaon b London, IMS. M. Karatadl end R. Boba! "Avaflabdity of Epidemiological Data on Humana E taoird to Animal Canriucyro. IL O nm k it Uvee and Production Volume,** Tnata jinrite Canrineyn w te Muty ureb 1S1-U7, IM2. f. King, Tmadfed Wafer. Rodale Presa, E m tut. Punnayfitnl* IMS. H. X ju te d g **ACaae Report Study ef Lung Cancer, O cn p aio w i E iponra and Smoking: III Elioiock Fractim of Occupational Es portarvi*". Som. f. N ed M m . HUh. IZ 2JM IX JIM. M. S. Legator, S. L. Harper and M. f. Scott, 7W fb etrk Cefedbe Hand- look, fohna HaoHne Prete, Bafeimero 4 London, IMS. C C Mnenei. On IptefihoklnnLCytokinee and Bre akthrough*. f. Am. Midi Ajwr. 9 k 4 L 1MX G. V. Molinavi A ln * at JLktiteubpeBnumRnteteeryCnacerDMtbs and fitte b m o f fetter>y U oeiros Affmfmg S iu n 'U u i W a d US Crotein Am Ite fbtim . US Gmgreso HR. WaaMngto* DC. lune IX M l |. f. Morgan>r. I n d e n im l^ V il eLt teUtefISmLeUwnntenniItRenMMtg and O m arterlattion TOwMTMV g 1^ rlW of W Nourodiui U ff. Dnwanar ted Protection Agency, Match TOO. b e T teG m rJrter Fttbmf Otertrr f if Chut Cnr "** * - The Crocrr Canted Cprtb te/te ter fteim , IMSOOOq Ette. Croerrald tM S codX ppV IO lN aM iropifkM kM il National Reaeaartt OauncX Tiamnify Titefeg: Steteiyue 4 f t t e n i u TO4. New York State Oifiartmenl uf InvkBum rotei Cinoceettfcm. Iteri Cm tueun iIti b y t e g ricwrte ro Arourotee k 0 IflOUL Auf Cri Rdbabg t ter Rterirfbu a/ ifce A ddil a Altero. Ghindate, O le Mrtb* IteMrm ttfbyttdhfer. ARuny, NY. Ducenb te. TOX Ote upathutel Safrey and Heabh Adurinbfrrtbn (OSHAV 1 4 * 4 c u b a , CTaardkafhm end Regulatimn mi M en titi O trou elienei Cwcteogena.** Fall Rrg. Oc fl5)c SCOTCTX fain. Z t IMO. O S H A E m b n u en d Maadc "teduscry Cmrupta WHO Anency (IARCT* Val. I N n X Sepaamae IM2. V PVM CM I^ RO e m j| v W W WM9RBEVMCAp v m whM X m a i ^ - e --------- -- n - - - a tt e . -- ^_ U e-_ __ a mPl--fVe w VI W pOWV WV_ *-- _____J 0 MHCIP0 rW n^Vi g fVm0a ---------*-> - J m i n_ _m ro. j o RmbkrSfc R P S IN Q , TOX V. L Pye. X fatridt and L Q unies. Garondetetcr Gantonmaebu ia * r Ubaadf ante UmieteityefPnwy4rante PreroPhBadeiphi^TO X Ragbtmr Cmtmt Cto i r o J tyydwrout Ca^kmd ed M k c Om> fetbnrfJMbrtefiro 1MOOX SeeiteDSN*. t OrCSCmOh U. Staffiteli and J. ^M agonee. fEdfcf'Xhcup klunal Cjn k g y roeb,>. Aro. M e Yn4 A m i S ri 271: M IX IWX H. Sridman. df 'Tiufcak iilk iof Eventoliy Develppmg or Pyiaqcct Cancer. Usbed S u r o I - CAdh Gronr fromadftr Qmmwm 2S; as-sxiM X UAW, TheC tef/* Hbrfgdac U r*K A Maerof/heCamrr Cetudbo* m te r ITO liti m ia d Union UAte, N n ew ter IMO. US Hauae e t Ripteettetehpifc P emocratk Study Gamap (Scncid Reperti Rnym'a W r AfcOro Rnmdb A Putte Morite Hrond. Wattdngaon, OC M y 2L TO4. US N tttend Canne Ite Heabtt SlatM ro Apetebiettd OnM Rdte ^e 72 Sdartut C unm ly Cabro rod Sto IfTMMX WRteX W .C <t tt T h rtary Fai and The Rbk of Brorot Cancer.** f i n Cm - U Meri. THc 243X 1M7.