Page 1 of Attachment G 
INDUSTRIAL PRACTICES SUBCOMMITTEE of the FEDERAL INTERAGENCY ADVISORY 
COMMITTEE on RECOMBINANT DNA RESEARCH 
COMMENTS: CHRISTINE OLIVER, M.D. , M.S. , for the OIL, CHEMICAL and ATOMIC 
WORKERS INTERNATIONAL UNION 
JUNE 18, 1980 
I want to thank the Subcommittee for its invitation to attend the meeting today to discuss 
the concerns of workers as industry prepares for the large scale application of recombinant 
DNA technology in commercial production. Anthony Mazzocchi, Director of Health and Safety 
for the Oil, Chemical and Atomic Workers International Union (OCAW), was not able to attend; 
so I am speaking in his place. I only hope that the allocation of 15 minutes to each speaker 
is not an indication of the seriousness with the 'liicommittee intends to take the comments. 
It is impossible to enumerate, consider and discuss the issues involved in that period of time. 
I will attempt to givd an overview of the problem based on the OCAW’s long and bitter experi- 
ence with the industrial sector and on my own more limited experience as a physician working 
for the Union. 
The OCAW represents 180,000 of the more than 97 million workers in this country. Our 
members are employed in the oil, chemical and atomic industries; many of those employed 
in the chemical industry work in pharmaceuticals and petrochemicals. The Union has a 
strong health and safety department and a long history of activism in the public health and 
s afety arena. The majority of workers in this country do not have the benefit of union or- 
ganization and support; many of them work in small, a ntiquated shops. Many of these 
shops are chemical factories. Some of them will eventually use recombinant DNA tech- 
nology as commercial application expands. There is no health and safety spokesperson for 
these workers. 
The concerns of the OCAW for its own and other potentially exposed workers as recombinant 
DNA technology moves from the laboratory into the industrial sector are several. First, 
workers at the point of production will be the first to experience the risks of this biotechnology. 
The health hazards now faced by our members and other industrial workers are many and 
varied. What does not vary is the fact that there are certain fundamental characteristics of 
workplace policy and practice that produce exposure to toxins and carcinogens at the job site. 
These include the following: 
1. The workers' Right-to-Know is ignored. Information essential to their self protection 
is not given to them: the generic names of the substances with which they work; the 
results of environmental monitoring of levels of expoxure; the results of toxicity data 
to which the company has or should have access; group morbidity and mortality data. 
2. Environmental monitoring for exposure to toxins and carcinogens is at best sporadic. 
Biological monitoring for the physiologic effects of these exposures is more systematic 
but often of questiormable quality; and the results are often interpreted by a physician 
more interested in preserving the health of the company than the health of the worker. 
3. Engineering controls are inadequate to control exposures. If they are sufficient under 
routine working conditions, they are rarely able to protect workers in the event of an 
accident or spill. 
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