2009 Articles

Delusions, Illusions and Ongoing Neglect of Hazard Recognition, Regulation and Control of Industrial Carcinogens

Stellman, Jeanne M.; Stellman, Steven D.

Since Doll and Peto’s 1981 monograph on causes of cancer, periodic efforts have been made to re-estimate the numbers and percentages of cancer cases “attributable” to various types of environmental and occupational exposures. We argue that much of this effort, especially in the occupational realm, is wasted, not because the information is not worth knowing, but because governmental initiatives to carry out needed studies, translate them into recommendations, and generate and enforce standards have been badly eroded and the system created by passage of occupational health and safety laws in the latter part of the twentieth century has become largely dysfunctional. For example, whereas NIOSH released over eighty criteria documents between 1975 and 1990, it published only one between 2000 and 2006. Furthermore, the increasing complexity of chemical products and potential exposures have made many classical risk assessment paradigms obsolete, while the fragmented nature of the work force and the rapidly increasing globalization of chemically-dependent industries has made epidemiological studies of workplace hazards increasingly difficult. We advocate replacement of chemical-by-chemical exposure standards with standards focused on process safety management, increasingly based on structure-activity relationships for chemicals for which human toxicity is not yet known.