Lorillard
Workplace Cancers: Politics Vs. Science
Fields
- Type
- NEWS, NEWSPAPER ARTICLE
- CHAR, CHART/GRAPH
- PHOT, PHOTOGRAPH
- CHAR, CHART/GRAPH
- Area
- LEGAL DEPT FILE ROOM
- Alias
- 03732527/03732530
- Site
- N14
- Request
- R1-004
- R1-037
- R1-059
- R1-037
- Named Person
- Blair, E.
- Bridbord, K.
- Califano, J., J.R.
- Doll, R.
- Gehring, P.
- Gori, G.
- Higginson, J.
- Hoerger, F.
- Kotin, P.
- Miller, A.B.
- Rall, D.
- Schneiderman, M.
- Selikoff, I.
- Weisburger, J.
- Wynder, E.
- Bridbord, K.
- Date Loaded
- 05 Jun 1998
- Document File
- 03732159/03732629/S and H Re Smoking and Health General Volume 3 780901790605.
- Named Organization
- Ahf, American Health Foundation
- Aihc
- Dow Chemical
- Environmental Science + Technology
- Hew, Dept of Health Education and Welfare
- Intl Agency for Research on Cancer
- Johns Mansville
- Mt. Sinai School of Medicine
- NCI, Natl Cancer Inst
- Niehs, Natl Inst of Environmental Health Sciences
- Niosh, Natl Inst for Occupational Safety & Health
- Nohs
- OSHA, Occupational Safety & Health Administration
- Oxford Univ
- Seer
- Wa Post
- Afl Cio
- Aihc
- Litigation
- Stmn/Produced
- Author (Organization)
- Environmental Science + Technology
- Master ID
- 03732159/2629
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1~7
Env'Fonmental Science &
Te 3ogy, Jan., 1979
Pages - 8
Workplace cancers:
politics vs. science
I Industry~faul~t~s the logic and the~~meth~odology~~of a recent
~
government ~.rtudy~ which attempts~to estimate future cancer~
deaths from present and past worksite exposures
Watch a tennis match to its con-
clusiom and you lcavc satisfied: the
resolution is dccisive, the winner
krto~%n. Follow the IOOCA cluinis ana
countercltri'ms on the estimates of
cancers of occupational origin, and youl
arc left in a disconcerting tizzy: the
resolution is unccrtain~ the consc-
qucnces monumental.
Except for the matter of rcsolution,
the tennis analogy holds up well in t'his
latest exercise in mulhcmatic manip-
ulation. The players are known: I I EW
scicntists vs. industrial scientists. The
_
basic equipment used by both sides is
idcnticali epiderniological studies and
bioslatistical methods. The court--
OSHA's cancer policy hearinE~ and
the prcss-is sharcd'. The rallic.,trc
fierce and cxciting, but whcn the
match of tltiti "estimates gtnnc" , is
played out, the spectators suill don't
know thc score.
Players ready? I'la~!
The opening serve wa,, ntadc on
September 11, when I II?«' Secretary
Joseph Califano, Jr., speaking beforc,
the AFL-CIO National Conference on
Occupational Safcty and Ilcalth
quoted from the thcniunrcleaticd I t'd_'W
study "Estimates of thc Fraction of
Cancer in the United States Related to
Occupational Factors," writteni byy
scientists from the National Cancer
Institute (NCl); the National Institute
for Emironmcntal I Icalth,Scicnccs,
(NIEfIS) and the National Institute
..
for Occupational Safcty and Health
(N105FI).
Califano noted industry's frequent
reference to the csliniatcs of 1' -5% ass
theoecupaiionai'contribution tothc
totol cancer burdan in the U.S. Then
he qltutcdl frrnn thc I1I.W study: "1f
Chc full conncquenccs of occuPational'
exposures in the present and the recent
past arc taken into,tccounU, estimatcs
uf at least 30'.tt-,appcstr much more
reasonablc; and tnay even be conser-
vative." Califl;tno charactcriecd the
report's findings as "alarming." As
cxpected, his stalemcnt received wide
media play; industry was not slow
in returning the servc.
That samc day. Perry Gchring, di-
rector of health and environmental
research for pow Chcmical USA, was
quoted in the tf'n.chirlgtorr Post as
..
saying: "Whaf it boilkduwnito is that
Califuno is all %Nct. Ille doesn'it h;vc the
data to support those findings.'.
Two wccks later, on October ?5, the
Antcric;in Industrial I Ic;tlth Council
(AIF{C), amassoci:rtion of 119 mcrn-
bcr companics and, 66 trade groups
formed sulcly to onr al"coordinatcd,
constructive" response to OSHA's
proposed cancer policy, held a press
conference to present its rebuttal to the
governmenU study, which it ternied
"exaggerated speculation." .
At the press confcrcncc, Fred
Flocrgcr, chairman of tihe All IC sci-
entific committcc, said that hc could
' charitabl~," tcrm the HEW study a
"poor paper based on infl,ttcd esti-
mat'cs of the population at risk, and
erroneous atiswnptionx in s4rtistics and
cpicicmiology."ln its introduction, the
AIIl(_ rcbuttul rcinfurces IlocrRCr's
statements with phrases that fault the
govcrnmcn0 study for using "qucs-
tionublc logic," "selective ... datti that
is ouUdmcd"and of "yuestionalblc sci-
cntiific v,ilidity," and "unsoun ' d mcth-
odi;'' which lead to "unscientific and
highly speculative conclusions." Sonic
of industry's criticisms, discusscd latar,
are valid, and are supported bz inde-
pendent scientists.
Despite these criticisms', the two
reports share sonicvery tcllih~ char-
actcrititics. Qothiwcre prepared hastily
for inclusion in the posthearing record
on OSI I'A's cancer policy. F3othihavc

HEW's Califano
NCI'.s Schrtnidermart
NIL'NS' h'rrll
been widely publicized. And neither posure to the carcinogen comparcd to
has been peer rcviewed'4 although,the tile number expected in tile gcneral
H'EW paper has since been widely popultiUion--which they dcriN.cd from
distributed for comment. In fact, it is studies publishcdlbctwccn 1947- 1978,
now being revised based on the cont-
mcnts received (which have been sur-
prisinglymeagcr to dittc), and will bc-
submittcd' to a scientific journal for
publication, perhaps later this year.
} I E1V: rankings change
Ten government scientists from~
NCI. N'IEI-IS and NIOSH preparcd'
thc government report. Although this
paper was written quickly, discussions
on the concepts and mct~odologics
containcdl in it had supposedly been
going on for months.
. According to scientists contacted by
ES& T. tile 10 contributors had long
felU that the l-5%cstimatcs of cancers
of occupational origin putl forth earlier
by John Higginson, director of the
International Agency for Research on
Cancer (Lyon. France), Gio Gori of
NCI, Ernst Wynder of the Americani
1lcalth Foundation (Valhalla, N.Y.)
and Richard Doll of Oxford University
understated the true contribution of
occupational factors. This is cspeciirlly
true, they, fclt, once Irving Sclikoff s
(Mt. Sinai Schoollof Medicine, New
York, N.Y.) data on asbestos-rclated!
discascsarc factored into tile calcula-
tions. They thcn began to develop wh,it
they considered to be more realistic
cstimates.
To predict the number of futurc
cancer dcaths which nrty be attribut-
ablc to past atibestos exposure, the
I IFyV scientists rclicd he;rvily on Si:l-
ikoff and coworkers generally well-
received work,, plus some Ilss than
well-defined cstimatcs of thc numbcr
of wurkcrs exposed, to asbcstos in the
U.S. since World War 111.
. To project annual excess deaths as-
sociatcd with occupational exposure too
five other carcinogcns-arsenic, ben-
zene, chromium, nickel and petrollum
fractions, including the aromatic hy-
drocarbons--for which ample datal
cxist, the scientists used a mathcmat-
ical formula. This calculation is a se-
ries of multiplications: risk ratio - the
number pf cancers expected from ex-
multiplicd by the numbcrof workcrs
cxposcd-a numbcr usually obtai'ncd
from the NIOSH-commii;sioncd Na,
tional Occupational Hazard Survey
(NQf 1S) conducted between 1972-74,
multiplied again byt'~he incidence for
tile tumor type induced by the cherni-
calL
The AIHC rcbut'tal argues that!
"serious crrors" were made in dcter-
mining all three of these multipliers.
For cxamplc, AIHC claims that the
risk ratiosuscd arcnot applicable to
recent workplace conditions, that! tile
estimates of thccxpo}ed population arc
"inflated," and that incidence rates arce
uselS intcrchangcably with mortality
without adjusting "for surviv,tl or
conipc.ting c wties of death."
A Canadian canccr epidemiologist,
A. B. M illcr, who rcccivcd a copy of
the IIE'V1' papcr from NCI's Marvin
Schneidcrman for review, agrecs, He
toldi L-.S& T thatl, in gcncral,"hc fccls
that the governmcnt! paper overesti-
mat'cs the number of people exposed
and f or the degree of risk.
kliller cites the cases for nickel and
chromium, with which he is familiar,
as incorrect cxtrapolations of risks
from a subgroup to the whole group.
Another example ol?ainiinapproprintc
cxtrapeflation, AII IC s,iys; is th,it (lrom
coke ovcn and gas workers exposed to
pok,nuclear aromatic hydrocarbonti
(I'NQs) to,all workcns potentiiil9y cx-
posed to I'NAs in olhcr indu~trics,
Nlillir quickly addsl how'evcr,,thai
tile I I I:W papcr is ai"uscfullcontribu-
tion bccause it will [stimulittc]'people
to cah:ulatc the numbers more ,iccu-
rately."
Crucial points in first set
The bulk of the difference in dis-
puocd cstimate rangcs;, I-5`%o vs. 20.
40%, may be cxplaincd! by asbestos-
related deaths, if you accept the gov-
crnmcnt calculatiun++: Inithc next three
decades, the government scicntists
predict thatlcxcesti canccr deaths front
past asbestos exposure may reach
.
NIOSN's Bridbord
2-2.3 million, or about 58' 000-75 000,
deaths per year. If this conics to pass,, `
atibcstos-relatcd deaths will, then
`
comprise 1'3-1 x%of all annual.canccr
deaths, assuming that total canccr
mortality reaches 400 000-450 000/y
in the next few decades.
Annuai excesscanccr deaths for the
five other carcinogens (box) may ac-,
count for another 10-2011% of thc an-
nual cancer deaths from; all causes.
The contribution to total annual can-
cer mortality made by asbestos plus
the five other carcinogcns may range
,
from 23-38%, accordin to HEW.
A[HC's bll~stin 03~~2528.
AIFIC bclicves that'scienlific evi-
dence does not support tile niugnitudee
of tile projt ctions made by the H EW
scientists. The Council takes HEW's.
pivotal argument-that for a~;bcs-
to!;--and! asks tile question: Arc we
today in the midst of tile cancer epi-
dcmic pi~edictcd by the governmcnt
study? To answer thi's, AI l IC analyzes
the casc for mcsothclioma, a very rare
type of cancer which serves as a
marker for asbcstos-induced~canccrs, .
Using very conservative assump-
tions and HEW-gcncraicd numbers,
AIIIC calcultttcs that we should be
seeing from 5000-10 000 deaths per
year from mcsatlhelioma. Instead,
AI I IC says, NCI's ll-ci'ty/statc Sur-
vcillltncc l:pidi mioli)ry and l:nd' Rc
sults Program (SEER ) tabulatCs only
950 deaths per year fi-om masotliclio-
noa, with no upwurd surge eviiJcnt..
Ni>llsci, says Schncidcrmun, a NC1
contriliutor tu the IIII;tiL' sludy,. Ile
poilnts out thaC deaths from mcsothc-
lionia have increased 1i25ON', during the
1970-76 period, and' that there has
been a highcr death ratc in men lhnn
in wanen, which is consistcnt with
previous industrial exposure. Further,
he counters, seven out of the 1I
SEER's cities/states werc not ship-
build4ngarcas during World War II,
and still we are finding incrcascs in the
disease. Nevertheless, there is still an
order of magnitude difference between
950 deaths and. the cpidemie-like
5000-10 000 deathscalculatcdl byAI'IIC. '

l
C
~ N~YVs .S'i!rAoJJ~ ~' ALM"s ll nergfr
Both Scaineidcrnutn and NIEIIS'
director David RaiL another cont'rib-
utor tu tlic HI:W study, feel that the
,.inpondcrables of diagno,is.' have
probably resultcd in an undcrreporting
of mcsothclioma, AIIIC counters by
saying thnt the publicity given to
World War 11 shipyard exposures to
asbestos probably results in an ovcr
reporting uf this rare cancer.
Whatever the true rate of rcporti'ng
may bc, ntcsothcliumu is not thc only
furrn of cancer induced by atibcstus.
According to III:W"s catcultttions,
somc 4:S -5.6 million people wcrc ex-
posed toasbestos in shipsards during
W'orld' War II, and another 3.5 G.5
/)un'`.c (ic'1irf7t,t;
While acknowledging tlutU work-
place exposures to asbestos have de-
clined, Schncidcriman recounts Chat
the first asbcstos standard was set au I2
p,trticlcs/niL in 1968, unly 10 years
ago; ,tnd that thii; was furthen lotticncd
to 2 rarticlcs/nol- only in 1976. Hc
points out'thau t'hcrc is sonic evidcncc
th:tt even 2 particli*,./'n1L is too high:
O51I A, in fact, is considering loN~cring
the st;tndard to U particlcs/mL,
Schneidcrman says.
To the charrc that I'il:W used
outd,ttcd dat,r. Sithncid'erman turns to
the rcgulatory, history of thc five other
carcinogens considered. W'itlhi the cx-
c:eption,of nickelhcsays, the dccrcascs
I)uu's Blhir
many, uother chemicals also, have,
hoNNcvcr, impruvcd Lrnn;iderably since
tficn." Althuugh the guvcrnment' sci-
cntists citt; a range of risk ratios fur
cach of thc fivc carcinogens, and never
usc the hio,licsti value, they do apply p
risk facttrrs as.oci,ttcd t+ith hcitt y cx-
posurc to workcrs thut m,ty not.ltov, be .'
"subject to [thut] heavy cxposurc," the
AI I IC rebuttal cnophusizcs.
Thc Council also rebukes the gov-
ernment scientists for their careless
interchange of cancer incidence with .
cancer mortalit'y. IloN~cvcr, at le,tst,
for asbcstos-induccd lung cancer, in-
cidcncc and mortality are virtually
identical, unless, ot cour.e;' a lung
cancer p;tticnt dies in an automubilc
accident, in u hich case lhis dcath cen-
million have been exposed to the min- iniczposurcr httvc been rcuthcr rcccnt,
eraf in other occupations. About 4 and "old dnt;rouglti to bc uscd."
million of thcse are believed to have In response to the chargc that the
been heavily exposed. And uf the 1972 -74 \OIiS data infft,tc thc c,ti-
heavily exposed \corkcrs who havcal- niat'es of the number of «orkers cur
rcady dicd, cpidemiolugic evidence rcntl% and aca'uufly cxposed'. Rall
indicates thnt'?0-?i'!9)died'from lung concedes that "thc NOl IS data crre not!
c<tnccr.7-10'!irdicd! fromi metiothelio- the `tror.ge;t'. but %kc have no, other
ma and K-9+'t,diud from g:tstrointcsti- data. Industry could'huvc +korkcd with
nal cnnccrs. us in the past and supplied better
AIf(C claimt; that HI;SS"s projac- data."
tion of futurcdeatlth from past asbes- Turning to the five carcinogcns,
toti exposure ovcrctitimates the number AI I IC chides the I'1G1V scientists for
of heavily cxposcd, World War I I using risk ratio,, obtaincd "I'romistud-
sltipyard %%orkcrs who arc still alive. ics of workrrs exposed in the
.
today; "disregards the fact that as- 1920's I95Q7s. Wurkhlacc conditiuns
bestos exposure has bccn declining by for knu%% n carcinogens and for ,r unat
i
%%or
ers an
f
k
d
both number o
by degree
'
of exposure in rcccnt, ycars: and ignures
any changes in smokinfg hubits;" whicli
anwng asbestos wurkcrs, would reducc
lung cancer mortality r,utcs signifi-
cantly. (l:vcn if the numbur of rrcvi-
ously exposed shipyard workcrs alive
today wcrc accuralcly known, precise
calculations oG future mortality would -
not be possible because the age distriF
bution of these workers, and the du~
ration an&cxtcnt of their exposures arc
not known.).
ttl:1V: hack on the offentiite
Sclincidcrnt,tn, studying the age
dititributioniof shipy,ard'"orkcrs dur-
ing World War Ii, found this working
population "very young"; therefore, he
bclicvcs, many more arc alive today
than "were guessed at (without age-
distribution data) by AIH!C."
tific:atv would not notc thc cause of
dc:tthiati lung cancer.
AIl IC says to I IE1S': double fault
Ini,uannrarizing thc dcficicncies ul":'
the government paper, AIIiC con-
cludc,: "By selecting high risk ratios
.rppl!icablc to a smalllgroup of highly
exposed worker.,,by inflating cstiinutcs
of workers actually exposed, by con-
fusing incidence with mortality, by
ncgli?ct'inug age and sex distribution of
worker cohorts and by confusing at-
tributabl'c risk witit statistical associ-
ation, the [1'IL`V] Paper :trrivcs at a
hemical' Number of
workers
potentially
exposed
isk ratios
Arsenic About 1.5 3-8 (for respiratory tract
million cancers) 1
Benzene About 2.0 About 5(for leukemia)
million
Chromium (trioxide & other About 1.5 3-40 (for nasal cavity &
hexavalent chromium million. sinus;,lung 8 larynx)
compounds)
Nickel (oxides) About 1.4 5-10 (for respiratory
million tract cancers)
Petroleum products About 3.9 2-23 (for lung cancer)
including aromatic million
hydrocarbons
.
Projected
excess
annual
cancers
7300
14000
CJ
7900W
9100
Source: FEW's"Estirnates of the Fraction of Cancer in the United States'RetSted to Qccupational.
Factors"
..n. .6 1 i --

t
speculative concfusion conccrIllTntg the
probabilities of an i'mmincnt! cancer
epidemic due to occupational
causes.
Kenneth Bridbord'; a NIOS'II scir
cntist whose unpubGshcd paper "New
Ilorizons in Occupati.unal Medicine"
supplied the philosophic~,l under-
pinnings for the IIEW rcporu, feels
"that even with its faults, whiclr arc
listed in the report itsclf, it still reprc-
scnt:s as good a referenced estirnate as
anything done before." If anything
13ridbord points oul', the I Istudy:
may underestimate the risk of cancers
from occupational exposure bccausce
the paper only considers a small num-
bcr of compounds: agricultural occu-
pations arc not included, which climi-
nates the vast number of workers cx=
posed to pesticides: and only a Iimitedl
number of cancer sitcs are notcd'1
(bladder cancers, for cxample, are not
estimated because thc data arc too
inadequate, E3ridbor,: says, to make
projections).
- The confines of tlie I I[:1V studv are
further restricted by not including skin
cancers and radiation exposures,
Bridbord notes. Moreover, thc epide-
miologic studies thntan uscd'doinot
follow workers to the end of their lifc-
tihies, so the cstimatcs of true risks
among 'thc populations at risk arc
probably low, Qridbordl contends.
Schneidcrnian an& Rall, of course,
concur.
Play suspended
The 11 f:W paper is now being rc-
vised: howevcr, the estimates will
probably not change substantially.,
Schneidern,an told f:S&'T that hc is.
"conrfortabllr with [,tliej estimatcs:"
Rall says that "20% is probably a goo&
figure." And 13ridbord feels thati "20%
%tiill hold pretty firm, although there
may be sonic adjustment on the higher
side."
Inithc process ol' revision, Schneid-
crnrcui sent the I i E«`' paper out to a
Icgioniof scientists. When asked if he
had heard from I IiprinsonI he rcplirrdl
"No, but then I haven't hcard from a
lot of peoplc.;" .
I ligginson, the author of the widely
quotud estimate that 60 90"s; of all
human cancers mayy bc associated with
environmental factors (including dict',
smoking and drinking habits, and
%%orkplace carcinogens),,has publicly
stated that the data in the I I E%V study
.'do nou make a good case," and by
cmphasizing occupational cmccrs, thce
report may be "detrimcntalto the best
iritcrests of canccr control."
John Wcisburgcr of the Amcrican~
Ilealth Foundation agrees with
Higginson: He told E,S&T that he
bcjicves 'that the HEW' paper m1f
places the emphasis on occupational
cancers whilc ignoring, or not properly
stressing, the major contribution that
lifestyle habits-smoking, drinking
and dirrt-make to thc total canccr
burden.
Selikoff, on the othcr hand,s;tys that
the "I-IIEW report doesn't deflect fromi
the more important contributions to
cancer [madc by such factors] as
smoking." On the contrary; hcstresses,
it rcinforccs "Ihc importance of con-
trolling those factors such as.moking
that are recognized as causes itndi
which can be controlled." The largest
U.S. manufacturcr of asbestosprod-
ucts, the Johns-Manvillc Corp. (Den-
ver, Colo,)', has an antismoking pro-
gram. Sclikoff says, that "should be
cited as evidence against Flil;ginson's
fears."
Adiantage of replay
Califano's motives for announcing
the results of the study at a union
meeting have been tluestioned by in-
dustry,. Etcyl [3llrir, Dow ChemicalPs
vice presidcnti, dircctor for ccaltih and
environmental sciences, is disturbcdibyy
the timing and the manner of its rc-
leasc, stating that Califano made
cancer "a political not a scientific
issue." Furthcrmore, Blair feels that
the study itself "discredits the Amcr-
ican chemical ind'ustry."
Rail counters by asking what better
forumdid Caliifano~havc than a labor
mccting, if, in fact, IIE1V's estimates
of occupational canccrs prove to be
realistic. "To havc withheld such in-
forniation from the public would be
unconscionable," Rulllstresscs..
Certainly the government study
N~as, in part, writtcn to bolstcr OSf1A'ss
proposed cancer policy, but it's pri~
mary purpose; the HEW scientists
clttim, was tojug complacent thinking.
Whilc not underrating the majorcon-
tribution made by tobacco smoking to
cancer mortality, the government of-
ficials were reminding othcr public-
health scientists to look for the occu-
pational componcnts-thc prcvcntablc
fractiion--of thc total cancer burden.
They were also reminding public-
hcalkh scientii;ts, ofcanecrs'basic
charact'erii;tacs: multiple, interacting
causes; arid' multiple stages of dcvcl-
opment and; its corollarylonglatcncy, periods. As Sclikoff told LS& T, "to be
auarc of the multifactorial infcrenccs,
and to use them arc two different
things." Miller agrees: "A lot! of us
tend to overlook the industrial com-
poncnts of the multifactorial causes of
canccr,"
The question nevertheless remains:
should the government scientists have.
made these points by cstiiriating future
cancers ofoccupational origin based on
a limited, if not poor, data basc'?
Sclikoff answers that the task the
government scicntistshadtoperforriv
was "a difficultione, an urgent one, but
an impossible one to complete with any
rigor or accuracy." I Ic feels that they
had the "guts" to address issues that
neodui reevaluation, and that they
"correctly enumerate and detail the
reasons why previous judgmcnts were
inadequate," especially why.thc one-
effect, effcct, one-cause approach, or as Scl-
ikoff terms it "the singll-slot ap-
proach" to thc classification of cancers
.
"is wrong."
Recognizing that the government
scientists used data bases (NOt-IS
data) that were sometimes "vcry thin,"
and made It:aps in assumptions that
research scientists would be faultc6 for
taking, Selikoff queries: "Should they
as public-hca{th scientists be frozen
into saying nothing" because the bodyy
counts aren't in'?
Sclikoff answers in the negative.
"Thrauthors of this report performed
a vcry valuable function in calling at-
tention to the difficulties in thc,past
evaluations, the critical factors that
must be taken into- account, thc inr
adcquacics of past data, and'thc im;
portance of proceeding to acquire more
accurate data." In short, he says, they
acted as responsible public-health of-
ficials.
Match to res03732530 .
ume
The government report has var-
iously been called a"uscful cxcrcise,"
a "numbers game," and a "political
witch hunt." Whatever its faults-and .
thcrc. arc many=it has stimulatcd'
fresh debrte, principally, licrhaps,
bccause industry fears the estimates
will be uscdto set public policy.
Pauli Kotinsenior vice president of
Johns-Manvillc in his posthcaring
submission to thc'OSHA cancer policy
record said, "I think there's a IcgiUi-
niatc right and needfor suchia docu-
ment," but hc implied that he would
like to see one of higher quality: Sol
would'the government scientists.
I lowcvcr, bettcr estimates will re-
quire better data: the number of
workers exposed't the duration and
extent of cxposurc; the age, sex and
health history of thc exposed workers;
andl thc precise formulations of the
compounds to which they are exposed.
The repository for this information is
industry. And industry will have to be.
more forthcoming with this informa,
tion or its v;ilid criticisms of the current
I I E1V study will'e be rendered mean-
ingless, and its right to future criti-
cisms negated. LRE
