GUIDELINES FOR A NIOSH POLICY ON OCCUPATIONAL CARCINOGENESIS

The Occupational Safety and Health Act of 1970 provides legislative authority for the Occupational Safety and Health Administration (OSHA) of the Department of Labor, “to set standards which most adequately assure, to the extent feasible on the basis of the best available evidence, that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure for the period of his working life.”.l An urgent and essential part of this standard-setting process is the development and preparation of criteria whereby the National Institute for Occupational Safety and Health (NIOSH) can recommend standards to OSHA. In the case of occupational carcinogens there is need for special, new regulatory approaches for the following reasons. 1. Recent decades have seen a considerable unregulated increase in the number and quantities of synthetic organic chemicals manufactured and used, the human impact of which, in the form of chronic occupational disease, notably cancer, is now becoming manifest. 2. Past regulatory practices, based mostly on post hoc epidemiological recognition and regulation, clearly make workers the subjects of involuntary human experimentation. 3. There are recognized inconsistencies between protection afforded the general public through environmental standards, and protection afforded workers through occupational standards. 4. Current regulatory practices for occupational carcinogens often appear to be based on misapplication of scientific concepts. Most of us here are agreed that some new and viable approaches are needed if we are one day to stem the increasing incidence of occupation-related cancer. Some of us even agree that accomplishment of this goes hand in hand with strong regulatory measures. I am not here today, however, to speak about details of a viable form of a Toxic Substances Act. Rather, I wish to speak, in the brief time allocated to me, about the outlook on occupational carcinogenesis as perceived by NIOSH. Thus, as a spokesman for NIOSH I wish to present for your information some of the considerations that have gone into the guidelines that are meant to reflect the NIOSH policy on carcinogenesis. These guidelines were formulated on the basis of consultation with experts in the scientific disciplines of carcinogenesis; by review of documents for the safety of drugs and food additives; from recent court rulings concerning ethyleneamine and 3,3-dichlorobenzidine; upon recent regulatory decision-making processes concerning aldrin and dieldrin; and by congressional mandate of the 1970 Occupational Safety and Health Act. It should be pointed out that these guidelines, as the name implies, are