This testimony concerned the issues raised by OSHA in its 9 February 1982 Advance Notice of Proposed Rulemaking for cotton dust. NIOSH was completing studies on five sectors of the nontextile or secondary cotton industry in which the spinning of cotton yarn and the weaving of cotton cloth does not occur. Studies have been completed for the cotton waste utilization industry and cotton ginning and the final reports were submitted with this testimony. Specific comments were then made by NIOSH concerning two surveys conducted by the American Textile Manufacturers Institute regarding the prevalence of disease and the efficacy of medical surveillance programs. These comments concerned selection bias, ascertainment bias, definition of disease state, analysis, action level, engineering controls, tiering, cotton dust sampling devices, medical surveillance requirements, and the establishment of a bronchitis and dyspnea grading system. NIOSH reiterated its conclusion that, in the interests of protecting the worker, the initial examination should remain as a preplacement function and that ample latitude be given to the examining physician, where appropriate.