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June 2, 1981

HAND

 

Mr. 1ark Cowan

Special Assistant for
Regulatory Affairs

Occupational Safety.& Health
Administration

Department of Labor

Room 8?2315

200 Constitution Avenue, NW

Washington, DC 20210

Dear Mr. Cowan:

How do you control members of the bureaucracy who seem to be
operating freely within and without government and who seem to
'have made a decision and now are advocating a position rather
than processing information for the appropriate policy decision?
makers?

et Enclosed are copies of two letters that we have recently
received. One is addressed to us from Dr. Joel Bender, Chairman
of the Medical Committee of the Formaldehyde Institute. The
other is addressed to Dr. John Higginson of the International
Agency for Research on Cancer from Dr. Peter Infante of OSHA.
Both letters concern the recent IARC review of the toxicity of
formaldehyde and its conclusion that no evaluation could be made
of the carcinogenicity of formaldehyde to humans due to the
insu?ticiency of the available data.

. From this common point, the letters diverge. Despite the
fact that Dr: Rang went to Lyons; France and fought-for and ob-
tained_voting rights in the review process;"Dr. Intante is dis-
pleased withleRC's conclusion and believes that the IARC working
group-ignoredgits own criteria for the evaluation of carcino?
gens. He requests IARC to reconsider its conclusion about for?
maldehyde and suggests that the NIOSH Current Intelligence
Bulletin on Formaldehyde be used to support a new conclusion that
formaldehyde is a carcinogen. Keep in mind that Drs. Infante and
Hang were the primary "movers and shakers? behind the issuance of
this bulletin, the credibility of which is seriously challenged
in the attached letter from Dr. Barry Demopoulos.

 . anHose 3 Huts

er's letter concerns Dr. Infants and Dr. Ken: and
tion about Dr. Kang's participation in the IARC
review of armaldehyde. The reason for his concern is the oer?
ceiued bis a-ainst formaldehyde that both Drs. Intante and-Rang
thaye=exhibited. ?Rather than approaching the issuetof formalde-
e< hyde toxicity inwa scientific, comprehensive and balanced way,
these OSHA representatives have become-advocates for the position
that iormaldehyde is a carcinogen; :They support their position
with preliminaryg?irrelevant, questionable or distorted studies
:g and ignore numerous animal and humanvstudies that contradict ,l
theirrargumentxr They then use their-own writings or statements
. of others that they promoted to support their own conclusion.
'This seems to us to be the ultimate in.circular logic. The
Formaldehyde InstitUte questions whether it is appropriate for
these government officials with an active predisposition towards
?government regulation of~formaldehyde=to insist on participation
in an independent~international scientific organization of_the?i*
stature of IARC.
The Institute has asked us for suggestions to insure the
independence of evaluations conducted by agencies such as IARC.

Would'you be so kind as to provide guidance as to OSHA's policies
on these matters so that we might-properly respond to our client?

Thank you for your assistance in this matter.

 

g?

Enclosures

cc: James Ramey
Jack Murray
Joel Bender
Don Morgan