SEPTEMBER 6-7 - MINUTES OF MEETING 
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To check that these techniques are used requires an inspection procedure 
and the involvement of an agency with regulatory authority. Dr. Parkinson 
cited his own involvement in promulgating regulations controlling the 
use of carcinogens in laboratories in California. The California regulation 
required the reporting of the use of these chemicals. At that time it 
was not known how many laboratories and concerns were using these chemicals. 
A similar problem exists in the recombinant DNA field. It is a rapidly 
mushrooming technology and without some type of reporting mechanism, contact 
with the laboratories using this technology will be rapidly lost. The California 
regulations also require that certain preventive techniques be employed if 
carcinogens are being used. Dr. Parkinson noted that there was much opposition 
from the universities; they said they had been using carcinogens for years and 
had no problems with them. Dr. Parkinson stated that, upon inspection, the 
commercial laboratories were found to employ better preventive techniques 
than seme university laboratories. 
Dr. Parkinson emphasized that to adequately protect the health of workers, 
one must combine regulations concerning education, preventive techniques 
that control the technology, and a medical surveillance program; a medical 
surveillance program by itself is inadequate. Dr. Parkinson stated that he 
would like to put together a proper program at the start. This complete 
program should contain education, technology and surveillance as one package. 
He questioned the legal situation at the moment regarding medical surveillance 
and laboratories using the techniques. He noted that the legal status 
of each laboratory depends on the location of that laboratory; there is 
variation in the surveillance program depending on the state. When the 
OSHA program was set up in 1970, states were given the opportunity to 
have their own state programs. Thus, seme programs are run by state agencies 
which are overseen by the Federal government; while other states decided 
to allow the Federal government to completely run their program. For 
example, California has a program. Cal -OSHA, which is overseen by the 
Federal government but run by the State while Pennsylvania has a Federal 
program. The California program controls laboratories in State universities. 
That is not the case in states like Pennsylvania which have Federal programs. 
In contrast, commercial operations are covered by OSHA regulations in all 
states. Dr. Parkinson noted that the OSHA regulations have a general duty 
clause under which inspectors could cite laboratories for violations that 
could lead to health problems. However, this clause is too vague and doesn't 
contain any specific directives. 
Dr. Chamot of the AFL-CIO then added a few comments concerning the letter 
sent by the AFL-CIO to the NIH (730). He stated that the AFL-CIO believes 
it is a serious mistake for NIH to get involved with regulating the work 
place. He emphasized that the NIH does not have the legal authority to 
regulate the work environment. He conceded that the RAC possesses a great 
deal of technical expertise in the science itself and in the practice of 
that science. However, this problem reaches beyond that expertise and goes 
into the questions of commercial production. Mechanisms for dealing 
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