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Page 2 of Attachment G 
4. Lalxdling of vessels and pipes containing toxic materials is inadequate to nonexistent. 
5. Morbidity and mortality data that is collected is rarely analysed in a systematic or 
epidemiologic fashion. Consequently, ad usters of disease resulting from specific 
exposures go undetected until late in their course. And prevention is obviated. 
6. Worker education programs are confined to larger companies, for the most part. 
These programs are usually sporadic. They deal primarily with safety rather 
than health issues and with acute rather than chronic effects. 
The industrial operation that produces biological products and uses biotechnology is no 
different from the industrial operation that produces chemical, metal, fibrous and other 
types of products. Hazardous exposures of workers to the byproducts of production and 
subsequent illness and disease will result from the same causes: inadequate engineering 
devices, failure of control systems, lack of information on the part of the worker, failure to 
label and failure to monitor — the environment or the worker. 
Second, screening for the "hypersusceptible" worker is now a common practice in many 
plants. The expanded use of recombinant DNA technology introduces the possibility of 
genetic manipulation of this "hypersusceptible" worker to modify him or her to make him/her 
compatible with the work environment. Th as the workplace itself does not have to be cleaned 
up. 
Third, the use of this technology for commercial production, particularly in the chemical 
and mining industries, may well result in significant job loss for our own members and 
other workers as well. The economic and health effects will be quite serious, not only for 
these workers but for the country as a whole. 
The NIH Guidelines for Recombinant DNA Research do not adequately address these 
issues. Compliance by industry is purely voluntary. It is inappropriate to have the same 
agency both promoting and regulating the use of any technology. And the Recombinant DNA 
Advisory Committee (RAC) has proposed (Federal Register, April 30, 1980, pp. 28904ff) 
the amending of the Guidelines to require membership by industry representatives. This 
state of affairs has been made worse by the recent Supreme Court decision to allow the 
patenting of microorganisms. I^dastry is thus being encouraged not only by their own self- 
interests but by government agencies and the federal judiciary to vigorously pursue the 
use of recombinant DNA technology for large scale commercial production. Under these 
circumstances the voice of the worker will never be heard; and the health and will-being 
of the worker will not be protected. 
Before the use of this technology for commercial production expands further, the 
development of control technology and workplace practices that will maximally protect the 
worker is essential. In addition, regulations that govern industrial use and application of 
recombinant DNA technology must be in place before rather than after the fact of commercial 
production. And these regulations must have the force of law behind them, with appropriate 
penalties for violation, if they are to be effective. The appropriate research and development 
agency is NIOSH; the appropriate enforcement agency, OSHA. To whom should fall the task 
of certification of industrial use of specific recombiannt DNA systems is less clear. In all 
three areas, however, meaningful input from labor representatives and from workers at 
the point of production is essential. A single labor spokesman on the RAC and 30 minutes 
before this sutxiommittee can not be considered meaningful input. 
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