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Page 3 of Attachment G 
Regulations that arc developed, whether by OSIIA, biy Congress or by an alternative group 
or agency, must address the following issues: 
1. Right-to-Know . Workers have the right to know what they arc working with, 
in what qua'ititics and with what known or predictable consequences . Without this 
information, the workers can not provide themselves with adequate protection 
guaranteed under the law. 
2. Environmental momritoring . Techniques of environmental monitoring should be 
developed in conjunction with the National Institute for Occupational Safety and 
Health and the Occupational Safety and Health Administration; and these techniques 
should be applied in a systematic and routine fashion within both the industrial 
production and the industrial research and devlopment facilities. 
3. Biological monitoring and medical surveillance. Biological monitoring and medical 
surveillance must likewise be carried out in a systematic and ongoing manner. 
a. All companies using recombinant DNA technology should be required to keep 
OSHA health and safety log forms relevant to the hazards of thes technology. 
b. National standards for medical surveillance programs specific for each class 
of organism and group of experiments should be developed by NIOSH and en- 
forced by OSHA. 
c. All workers potentially exposed to recombinant DNA material should have 
the opportunity to participate in such surveillance programs with guaranteed 
economic and seniority protection. Members of their families should be 
similarly evaluated when appropriate. 
d. A central registry for recombinant DNA -process associated illness and 
disease , proven or suspected, should be established and maintained with NIOSH. 
e. Epidemiologic analysis of morbidity and mortality data should be errried out 
as it accumulates; so that trends can be detected quickly. 
4. Emergency spills. A set of national standards should be developed for handling 
emergency spills, not only to protect the worker but also to protect the general 
public. 
5. Worker education. Relevant and comprehensive worker education programs must 
be developed and required for all workers potentially exposed to recombinant 
DNA materials. 
In summary, chemical hazards have not been eliminated from industrial production; 
nor have they been adequately controlled. Biological hazards are different only in that they 
are more difficult. to monitor. Accidents are inevitable. As commercial use increases, 
production will increase. Job speed-up will result. Accidents will increase. And 
hazardous exposures will increase. These hazardous exposures will affect not only the 
workers themselves, but also their vamilies and the public at large. Well known examples 
are asbestor and lead. And like other occupational and environmental disease, these will 
in many cases be subtle and difficult to detect without careful scrutiny. For example, 
urinary tract infections and diarrhea are common illnesses. Unless causal organisms are 
carefully classified and compared to those in use in a laboratory or factory, the occupational 
link will go undetected. 
The Oil, Chemical and Atomic Workers International Union believes that adequate pro- 
tection of the worker from harmful exposures to recombinant material is impossible. 
[ 435 ] 
