In this testimony the need for standards for the control of 14 chemical carcinogens listed in a petition from OSHA drafted prior to July of 1972 was supported. The approach proposed in the draft from OSHA was clearly a work practice and not a use permit standard. NIOSH agreed that detailed work practices which would effectively control exposure to these 14 different compounds would be desirable, but cautioned that the goal will be difficult to meet and urged the passage of a use permit system. NIOSH stressed that the institution of a work practice standard at this time would be a deterrent to later instituting a use permit standard. NIOSH supported the identification of carcinogenic compounds as those whose composition of identified carcinogens must be 1 percent or more by weight. NIOSH requested that the wording be changed from its present form, which would limit the scope and application of the proposal so as to effectively exclude from control those compounds produced as by products of a specific operation such as coke oven emissions. NIOSH supported the reporting requirements to the Assistant Secretary and to the Director of NIOSH by industry of those workers exposed to carcinogenic compounds. The appropriateness of the requirement for environmental surveillance was questioned, but the requirement that industry submit a plan for medical surveillance to OSHA for approval was supported.
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