NIOSH Testimony on Identification, Classification and Regulation of Toxic Substances Posing a Potential Occupational Carcinogenic Risk by E. J. Baier, June, 1978.
This testimony concerned proposed rulemaking by the Department of Labor (OSHA) in relation to regulating exposures to potential carcinogenic substances encountered in the work place. NIOSH shared OSHA's concern with regard to the development of new procedures for the regulation of occupational carcinogens. The areas of the proposal addressed in this testimony included terminology, classification of chemicals, collection and evaluation of data, determination of exposure limits, and model standards. Under terminology, NIOSH took exception to the use of the term toxic substance and its equation with the term carcinogen since carcinogens are only a subset of toxic substances. The definition of potential occupational carcinogens as included in the proposal was deemed acceptable. The steps by which chemicals were classified into the categories of carcinogens were reviewed. While OSHA called for an alphabetical listing of the large group of potential carcinogens, NIOSH suggested that a preferable alternative would be to set priorities for evaluation of the substance based on an estimate of the degree of potential occupational hazard. Concern was also expressed regarding the adequacy and soundness of animal and human data. A series of questions from OSHA was attached along with the respective responses from NIOSH.