This testimony offered a review of a report submitted by the American Textile Manufacturers Institute (ATMI) dealing with medical surveillance data in the cotton textile industry. This review was restricted to comments on the shortcomings of the methodology used in the study rather than on any of the data presented. The ATMI study used seven member companies for its investigation. NIOSH contended that these seven companies were not likely to be representative of all 200 members of the ATMI or of the textile industry as a whole. ATMI asserted that the companies which responded to the questionnaire from which data was taken for the report were those companies who have made greater efforts to reduce exposure levels and have achieved lower overall exposures than the companies which did not choose to respond. The study was actually based on data gathered for compliance purposes and not on a statistically sound strategy which would be essential for making inferences from the study group to the whole population from which the selected study group came. NIOSH also questioned the accuracy of the pooling of data gathered from different sources for compliance purposes and provided several examples where questions arose about the pooling methods used and the completeness of the results thus obtained. NIOSH concluded that, in spite of the large size of this second report by the ATMI, it provided no more illumination of the problem than did the first report and should be disregarded by OSHA in its rulemaking efforts.
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