Dr. Paul Kotin Before the OSHA Advisory Committee on Construction Safety and Health on the Proposed 0.5 Fiber Standard (1976)

On January 22, 1976, Dr. Paul Kotin, J-M's senior vice president for health, safety and environment and a former head of the National Institute of Environmental Health Sciences, spoke to the U.S. Department of Labor's Standards Advisory Committee on Construction Safety and Health against OSHA's proposal to lower the asbestos limit from 2 to 0.5 fibers per cc. The file holds a 13-page transcript of his talk circulated by the Asbestos Information Association/North America, the 33-page official transcript of the session with his talk and the committee's questions, and pages of the federal asbestos standard. His first slide rated the evidence that asbestos causes asbestosis as complete (+++), mesothelioma and lung cancer as strong (++), lung cancer with a question mark for cigarette smoking as a "co-factor," and gastrointestinal and laryngeal cancer as weak or speculative.

What it shows

Kotin argued that OSHA had drawn conclusions its sources did not support, and he closed by calling the concept of a "no effect level" "untenable" in a particular sense: "every person over 45 in this room, with the exception of the rare highly resistant, has circulating cancer cells in his body at this time," yet a threshold for cancer "does exist." J-M's medical chief thus accepted that asbestos causes asbestosis and mesothelioma while opposing a tighter limit. NIOSH answered the same question in December 1976 by finding no safe level and recommending 0.1 fibers per cc (NIOSH Revised Recommended Asbestos Standard). See also OSHA Asbestos Standard.

In Johns-Manville's chronology

Johns-Manville's own chronology of what the company knew describes this document as follows:

OSHA proposes 0.5 f/cc. Kotin testifies against reduction on 1/22/76.