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A Occupational disease disclosures more future shocks? by Stephen Crapnell The past year saw ominous occupational disease disclosures surface with troubling frequency. With more government, labor, and industry resources being directed to occupational health, will 1978 be a year of progress against occupational disease, or will the troubling disclosures keep coming? Occupational health hazards produced a string of startling disclo sures in 1977. In case after case, substances thought to be safe, or at least safely under control, were dis covered to produce hormonal changes, sterility, and cancer. Here is a brief recap of some of 1977's most troubling occupational disease disclosures. Benzene: On April 15, NIOSH notified OSHA that a study of workers exposed to benzene at two Ohio Goodyear Tire and Rubber Company plants revealed an exces sive number of deaths due to leukemia. Two weeks later, OSHAboss Dr. Eula Bingham issued an emergency temporary standard (ETS) for benzene, effective May 21, that reduced permissible worker exposure from a previous level of 10 parts per million (ppm) to 1 ppm. Over 150,000 workers in the U.S. are exposed to benzene. But before the ETS could go into effect, the American Petroleum Institute, the National Petroleum Refiners Asso ciation, and 15 petroleum com panies obtained an injunction in the courts. On May 27, OSHA pro posed a permanent benzene stan dard. Public hearings were con cluded on August 10, but as we go to press, the final standard has not been issued. DES: On April 28, the Oil, Chem ical, and Atomic Workers Union (OCAW) requested that OSHA de clare a situation of imminent danger at Dawe's Laboratories, Inc., Chicago Heights, 111. OCAW told OSHA that 9 out of 17 male em ployees exposed to the synthetic hormone diethylstilbestrol (DES) complained of breast enlargement and one worker had already had surgery to remove his enlarged breasts. Two more workers com plained of impotence. OSHA inspected and cited Dawe's for three willful serious vio lations, four serious violations, and proposed a $34,000 fine. Later, Dawe's was cited for another willful serious violation and a failure-toabate violation. At presstime, Dawe's had ceased production of DES, but was contesting the cita tions. The case is pending as we go to press. Acrylonitrile: On May 23, E. I. du Pont de Nemours informed NIOSH that an epidemiological study of 470 workers at its textile fibers plant in Camden, S.C. showed that workers exposed to acrylonitrile had devel oped 16 cases of lung, colon, and other cancers, compared with an expected company rate of 5.8 and a national rate of 6.9. Du Pont low ered worker exposure from 20 ppm to 2 ppm. On July 1, NIOSH issued warn ings that on the basis of the Du Pont study and an interim report on a Manufacturing Chemists Associa tion study, which showed rats fed or inhaling acrylonitrile to be develop ing a variety of tumors, acrylonitrile should be handled "in the work place as if it were a human carcino gen." NIOSH also apprised major manufacturers and users of the pos sible adverse health effects associ ated with acrylonitrile exposure. Some 125,000 workers are poten tially exposed to acrylonitrile. On June 28, OSHA requested in formation on acrylonitrile in order to determine whether or not to issue an ETS. On September 29, NIOSH continued on page 52 ALCOA0004607 December 1977/OCCUPATIONAL HAZARDS 11 "Sixteen permanent health standards have been set in the seven years OSHA has been in business. That's absurd when there are two million chemicals in existence and 25,000 known toxic substances cited by NIOSH. ..." continued from page 51 recommended that worker expo sure to acrylonitrile be limited to 4 ppm, or 8.7 milligrams per cubic meter of air, as determined by a 4-hour sample collected at 0.2 liter per minute. DBCP: On July 28, Occidental Chemical Company closed the ag ricultural chemical operations in its Lathrop, Calif, plant after learning from fertility tests that 14 of 27 men handling the pesticide dibromochloropropane (DBCP) were either sterile or had very low sperm counts. On August 11, Dow Chemi cal Company, a basic producer of DBCP, closed its plant manufactur ing DBCP in Magnolia, Ark. On August 16, OSHA sent tele grams to 75 companies manufactur ing DBCP asking that they take ap propriate action to protect workers from exposure to the chemical. On August 23, OCAW requested that OSHA issue an ETS for DBCP lim iting exposure to 1 part per billion (ppb), the lowest detectable level. OSHA responded with an ETS for DBCP limiting exposure to 10 ppb over an 8-hour period and to a ceil ing level of 50 ppb during any 15minute period. In announcing the ETS, OSHA cited the sterility test findings and animal studies which showed DBCP causing cancer in two species and two target organs, the stomach and mammary glands. When OSHA later determined that DBCP was detectable at levels lower than 10 ppb, it issued a pro posed permanent standard with an exposure level of 1 ppb. Little wonder that a major OSHA priority in 1978 is serious health hazards. Carcinogen policy The cornerstone of OSHA's oc cupational health effort in 1978 will be its proposed generic carcinogen Secretary of Labor Ray Marshall: OSHA's proposed carcinogen policy will be a major breakthrough. policy, which Secretary of Labor Ray Marshall has described as rep resenting a major breakthrough for OSHA. "Trying to control car cinogenic substances on a case-by case basis is like trying to put out a forest fire one tree at a time. In stead, we are proposing a systemat ic way of determining which toxic substances require emergency at tention by OSHA," Marshall said. The proposed policy sets proce dures for regulating worker expo sures to potential occupational car cinogens, policies to identify and classify such substances, and estab lishes three model standards for use in rulemaking involving specific substances. Under the proposed system, OSHA or any other party could submit information to the Secretary of Labor concerning any toxic sub stance. The Secretary then pub lishes a notice of receipt of this in formation in the Federal Register, OCAW President A. F. Grospiron: Un happy with OSHA's progress in promulgat ing health standards. though he may delay publishing this notice for up to 180 days if he is aware that additional relevant in formation is currently being pre pared. A public comment period of 30 to 60 days follows, after which a notice classifying the substance into one of three categories must be pub lished within an additional 30-day period. In especially pressing situa tions, the Secretary may issue an ETS without waiting for a comment period. Category I would contain sub stances whose carcinogenicity has been established in humans, in two mammalian species of test animals, or in one species if those results have been replicated. After being classified in Category I, a substance would then be the subject of the proposed model emergency tempo rary standard, followed by a Cate gory I model permanent standard. Under this procedure, rulemak ing debate for specific substances 52 OCCUPATIONAL HAZARDS/Dacember 1977 ALCOA0004 606 continuedfrom page 54 lieves the policy would provide a predictability of response on OSHA's part. He favors the accep tance of animal carcinogenicity as a test for human carcinogenicity. His lone reservation:.setting worker ex posure levels for carcinogen stan dards at the lowest point that is technologically feasible, rather than at a zero exposure level. Sheehan also observed that the carcinogen policy had received ad vance billing as a generic approach to standards-setting, and said, "I don't think this is a true evaluation ofwhat the document does. The pol icy says how you will promulgate standards. OSHA must still decide whether to set standards for classes of carcinogens or go substance-by substance." Timetable All materials and written tes timony concerning the proposed carcinogen policy must be filed for the hearing record by no later than January 9, 1978. An informal hear Introducing simple, accurate noise ( recording GenRad's new 1985 DC Recorder is ideal for industrial, laboratory, and community noise recordings where a permanent strip-chart record of noise level versus time is desired or required by law. It comprises a complete sound-level measurement/recording system when used with GenRad sound measuring instruments. Simple setup, accurate results Input voltage ranges are matched exactly to the dc output of GenRad instruments for quick, guess-free calibration and setup. ANSI/IECType 1 accuracy when used with GR 1933, 1981, 1982. and 1945 Portable "go-anywhere" operation on rechargeable internal battery Operates from ac line or external dc source, also 50-dB direct-reading dynamic range Chart speeds from 2 cm/hr to 60 cm/min 20-meter long, fan-folded chart paper has provision for noting pertinent data about measurement conditions Specially designed for noise recording but can also be used as a stand-alone Expand your GenRad sound-level meter into a sound recording system with the 1985. It makes sense to use "matched" instruments. Write or call for complete details. GenRad, 300 Baker Ave., Concord, Mass. 01742. (617) 369-8770. GenRad Write No. 70 on reader service card SS OCCUPATIONAL HAZAROS/December 1977 ing is scheduled to begin March 14, 1978. OSHA sources estimated that, barring legal challenges, the car cinogen policy could be in effect by the end of next summer. However, both industry and labor spokesmen believe that court battles are ahead which might delay the policy's im plementation by 1 to 2 years. Standards in store Other health items on the OSHA agenda for 1978: The worker's right to know what dangerous substances he or she is exposed to. A recent study by NIOSH, entitled "The Right to Know," found that "employers were often not aware of the chemi cal composition of the substances used in their plants" and "the wide spread use of trade name products and lack of a uniform system for labeling hazardous materials makes it difficult for workers to know the nature of substances they are ex posed to. This problem is com pounded by the frequent claim that product ingredients are trade se crets, even though ingredients may be known to be toxic or even cause cancer." In response to this prob lem, Under Secretary of Labor Robert J. Brown announced in Oc tober that "... a generic standard is now being prepared to regulate the labeling and identification of all substances. We believe that work ers' knowledge of what they are handling is essential to the im provement of conditions in our workplaces." Development of a standard cover ing worker exposure to certain pes ticides. This standard is likely to be a generic standard and has been spurred by concern over such pes ticides as DBCP and EDB. John Froines, director of the Of fice of Toxic Substances in OSHA, told us that by the end of January, OSHA hopes to have issued final cotton dust and lead standards. De pending on when these are com pleted, OSHA will then proceed with a final sulfur dioxide standard. By the end of 1978, OSHA hopes to issue standards for asbestos, to luene diisocyanate, abrasive blast ing, silica, and chlorinated hydro carbons. And there's even an out side chance that the long-awaited new noise standard might surface next year. 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ILLINOIS 60106 312/595 0800 TELEX 28 2549 IN CANADA: SAFETY SUPPLY COMPANY. TORONTO Write No. 6# on reader service card December 1977/OCCUPATtONAL HAZAROS 58 ALCOA0004609 "... The widespread use of trade name products and lack of a uniform system for labeling hazardous materials makes it difficult for workers to know the nature of substances they are exposed to." approach to a complex problem. All carcinogens are not alike. Some are weak; some present a lot of risks to many people; some present very lit tle to very few. OSHA proposes to treat them all alike. The resulting system will be easy for government to administer, but excessive and wasteful for everyone else. Em ployees can be adequately pro tected by dealing with carcinogenic substances on a case-by-case basis,, applying professional knowledge, judgment, and experience to deter mine what specific protective steps are necessary for each. Acceptable exposure levels based on `no effect' levels can be established in many cases." continued from page 53 Ralph H. Harding, Jr., president of the Society of the Plastics Indus try, called the OSHA proposal "a `quick fix' method of dealing with the admittedly difficult task of re ducing the risks of occupational health hazards.'' Harding criticized the proposal for "placing undue re liance on limited animal tests to demonstrate carcinogenesis.'' He questioned the validity of two ani mal tests or a single replicated ani mal test being extrapolated for car cinogenicity in man. Harding also criticized OSHA's key tenet that th^ no safe threshold for a potential carcinogen and called for the creation of "^medical review and assessment board'' to examine animal test data prior to any OSHA enforcement action. The Manufacturing Chemists As sociation (MCA) expressed "seri- John Froines, director of OSHA's Office of Toxic Substances: First priorities are cot ton dust and lead standards. ous concerns'' with OSHA's refus al to recognize degrees of car cinogenic strength. MCA said that "Better guidelines are needed for determining the acceptability oftox icological data, resulting from ani mal studies and epidemiological in vestigations. '' MCA called for clarification of the decision-making procedures involved in choosing a "suitable substitute" for a regu lated carcinogen and added that notice of such a substitute "should appear in the Federal Register so that affected parties will have an opportunity to comment before a final ruling is published." Finally, MCA said that "performance stan dards rather than specification standards to achieve desired per formance should be clearly stated in the regulation." A spokesman for Du Pont called the OSHA proposal "a simplistic Labor for It OSHA's proposed carcinogen system gets high marks from labor. OCAW Legislative Director An thony Mazzocchi called it "a seri ous move forward in the right direc tion," though he said that OSHA should have included a rate reten tion provision. Louis Beliczky, United Rubber Workers' director of industrial hygiene, said the cancer proposal is a "good policy," but added, "I see some problems in that management will automatically challenge the ETS's in court." However, Be liczky added that even if the car cinogen standards are challenged, OSHA will have succeeded in get ting more carcinogens recognized as such. John J. Sheehan, legislative di rector of the United Steelworkers, said of the policy: "It's good. There definitely should be a carcinogen policy, and we find that the content of the proposed policy, for the most part, is acceptable." Sheehan be- continued on page 56 54 OCCUPATIONAL HAZAflDS/Decnl>r 1977 ALCOA0004610 /Iwoufcfb* limited to: whether* suB*-*' stance was correctly classified in*:=i Category I; whether tteiiaemfarufcfrT- was correct in detei%i|iwgtht theft^. Category I classification no#, be re* butted; Whether the lowest fragility The AFL-CIO is establishing- a pected to give final approval as soon exposure limit was selected o: Workers Occupational Health and as funding details are worked out-- whether- there are suitaole Iej haZdulous subsuiutes. whether substance has unique prope that make provisions of the model inappropriate; and tfte environmen Safety Institute that will doubtless be heard from in 1978. Sheldon Samuels, Director of Health, Safety, and Environment for the AFL-CIO's Industrial Union probably sometime this montb.\Theinstitute is to be supported pletely by union money. OCAW president Grospiror Chairman of the AFL-CIO Standing tal unpacLsf the subsTance's regula- Department, told Occupational Committee on Occupational Safety tion Hazards that the institute will give and Health, explained the institute's Category II substances would be labor the ability to deal with the sci value to labor in a recent speech: those whose evidence of carcinoge nicity was only suggestive, oris positive in only one species ananoti yet replicated.Classification in this category would, be followed \y* entific basis of health policy. The institute will be staffed with a physi cian, epidemiologists toxicologist; licensed professional engineer-, in dustrial hygienist,: educator, law "The creation of a workers' job health and safety institute signals the end ofan era for labor in occupa tional health.-- an era where our ignorance of occupational hazard^ rulemaking utilizing the model pei manent standard for Category H Category III substances would be yer, and information specialist, and will have funds available to retain ^outside consultants. A preliminary forced us into a reactive position The resources of a labor institute mean that labor will no longer have those- which require further inform mation. OSHA would keep-a list ofi these substances, publish them in the Federal: Register; and request! Tom EPAy- NIOSH; the National* Cancer Institute, and the Consumes ^arch for staff is already under way. The AFL-CIO's Standing Committee on Occupational Safety and Heafthvbas given the institute provisionaPapm-oval, and the union's ExecutivS-Council is ex- to wait for a crisis to intervene; but will be able to move agraeisively towards preventive occupational health practices, where crises will be anticipatedancTprevented before they occupS^W. Product Safety Commission any in* formation they might haver-on-th*r substances. A final classification? Category IV, is reserved for those substances, which OSHA believes are not cuca rently found in the American work place, and involves no regulatory) action. sure level for carcinogens exists) whether animal data could be ac cepted as evidence that a substance could cause cancer in man, and the bodies have turned tip* as definite* evidence." *-------- ------------ - The second tenef upon which OSHA's proposed carcinogen pot* OSHA objective*^ ! appropriateness of regulatory re- icy is based is: "A toxic substance, . quirements such as monitoring or determined as a carcinogen in a OSHA- has. based the proposed recordkeeping. In the past, these mammalian test animal system, as carcinogen policy on three essential ; debates have slowed the stany defined, is to betreated^MMiafiQL. tenets- The first is that*."the terns, dards^setting process and- brought matter as posing a carcinogenic risk `carcinogen', although^ admittedly* criticism from the Government Ac "TuTiumahs^' difficult to define scientifically): counting Office, the House Com The third tenet is that OSHA will must be defined for pusposesL o& mittee on Government Operations establish as a general rule that overall regulatory acdvityaU. <Th- and from some medical scientists ` `when OSHAis dealing with a toxic tenet holds that though medical and and virtually all labor leadei scientific debate contmuesconcem* ipIeToCAV substance; identified as a carcino gen. . ... the permissible exposure ing the nature of cancer; OSHAas a \regulatory agency cannot afford to sit idle and allow workers to- die from cancer caused by occupational 'esident A.F. Grospiron lashed ut at OSHA on this subject; "Six.eenr permanent health standards been set in the seven years limits will be set as low as feasible; In cases where there are suitable substitutes that are found to be less hazardous to the worker, no occu health hazards'. The proposal points- SHA has been in business. That's pational exposure: will be permit out; "___Congress mandatedthat bsurd when there are two million- ted." . standards, should not be postponed hemicals in existence and 25,000 because definitive medical or sciens tific evidence is own toxic substances cited by IOSH in their annual Registry for Industry's response Toxic Effects of Chemical Sub Industry spokesmen laud OS An underlying aspect oftinstenet stances; Another 2,000 substances HA' s aim of reducing worker expo is that because OSHA has not had a have been indicted as potential car sure to occupational carcinogens, generic policy for dealing.with car cinogens in the NIOSH Suspected but they are generally critical of cinogen regulationv it has been Carcinogens List. What makes the way in which OSHA is going dragged into repetitive debates over them potential rather than actual aboutitc: issues such as whether a safe exi icarcinogens is the fact that no dead continued on page 54 ALCOAO 004611 OcamCwr 1977/OCCUPATIONAL HAZARDS S3