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a screen or a nonscreen are much more profound because they really involve the future livelihood of people.
Mr. GORE. I would like to thank all of you for being here. I said a couple of times yesterday, I haven't said today, that one of the reasons we are pursuing this so avidly in a series of hearings is the anticipation on the part of the subcommittee that we are going to see a lot more of this genetic screening technology, particularly with the use of HLA antigen screening and the pre-existing incentives that many employers have and feel they have to use techniques as soon as they become available.
And the way in which these issues have been joined and addressed in this specific case, I think can help us, I hope can help us deal more sensibly and rationally with similar issues as they occur in the future, not to diminish the urgency of this particular issue, which I think is substantial.
I think your testimony here today has been extremely helpful in dismissing some of the irrational elements that cloud understanding of these issues. I thank you all for participating. Thank you
Our next witness is Dr. Bruce W. Karrh, medical director, of the Du Pont Co., and without objection, Dr. Karrh, your prepared statement will be included in full in the record. At this point, we invite you to proceed with any or all of it as you see fit.
I would like to welcome you to the subcommittee. You are accompanied by?
Dr. KARRH. Mr. Gerald Hapka, counsel from the Du Pont Legal Department.
STATEMENT OF DR. BRUCE W. KARRH, M.D., E. I. DU PONT DE
NEMOURS & CO., INC., ACCOMPANIED BY GERALD A. HAPKA, ATTORNEY
Mr. GORE. Welcome. Glad to have you as well. Please proceed with your statement.
Dr. KARRH. Thank you, Mr. Chairman. Let me start off by saying I don't mean to be unresponsive to the questions that you raised in your opening statement today, but my written testimony which has been submitted to the committee as well as the statement that I will give verbally today, were written in response to the specific issues that you raised in your October 1 letter to me.
I will, however, be glad to try to answer any questions on your opening statement at the end of my oral statement.
I have been in the practice of medicine for approximately 19 years, both in the military, in private practice and as an occupational physician for Du Pont. My experience has been spelled out in greater detail in the written testimony which you have copies of.
What I would like to do today is summarize that written testimony and direct my comments to questions that were raised in your letter to me. I also want to comment on the methods we, at Du Pont, employ to determine whether or not our employees are sensitive to the substances to which they might be exposed in the workplace. It is Du Pont company policy to provide a safe and healthful workplace for employees.
We do not exclude certain individuals from job assignments as a substitute for achieving safe exposure levels for our employees.
Du Pont does not conduct genetic screening of its employees, for purposes of employment, job placement or promotion, and I am not aware of any other company which does.
Du Pont does not conduct any cytogenetic surveillance of its employees.
Du Pont does offer to test black employees and black job applicants for the sickle-cell trait. Du Pont does not use the sickle-cell blood test to screen for employment, job placement, or promotion. This testing was initiated at the request of a group of black employees in the Wilmington, Del., area.
Positive test results are provided only to the individual for use with his or her personal physician. The results are retained in the employee's medical file on a confidential basis.
However, as set out more completely in my written testimony, even this use of sickle-cell testing for the private use of our employees has been publicly misconstrued.
As a preface to my remarks, let me state my understanding of genetic and cytogenetic screening. Genetic screening tests are those which determine whether a person has a heritable physiological abnormality.
Cytogenetic screening tests are those where human chromosomes are cultured and examined microscopically to determine whether they have been altered by outside influences, such as chemical exposures.
With that as background, I would like to elaborate on some of the concerns raised in your letter.
Your letter states that, "Diagnostic screens for particularly highrisk groups are being increasingly utilized in American industry,” and that application of this testing technology is still in the developmental stages.
The concern implicit in these statements is that when an individual's health status plays a role in important employment decisions, such as hiring, placement, and promotion, the assessment of that person's susceptibility to particular workplace exposures should be based on criteria which are sound scientifically and judiciously applied.
The concern is legitimate, and one with which I wholeheartedly concur.
Accepted medical screening tests are an important part of occupational medicine and, though genetic tests may be useful in a research setting, their utility in occupational medicine has not been demonstrated.
Thus, aside from any ethical or policy questions they raise, they are simply not practical tools and to the best of my knowledge, are not being done in industry. Instead, occupational physicians use the same well-established medical tests employed by private practitioners serving the general public to assess the health of employ
In addition, certain biological monitoring tests are used to assure that workers are not absorbing harmful amounts of substances to which they are potentially exposed.
Your letter raises six questions, the first three of which ask: Whether existing genetic tests are accurate; whether they are appropriately predictive; and what level of predictability from these tests is desired.
Although I am not an expert in the scientific methodology used to develop these tests nor on their general applicability, I am familiar with the utility of the serum alpha-1-antitrypsin SAT test and the glucose-6-phosphate dehydrogenase, G-6-PD, tests in an occupational medical setting, and with the sickle-cell test I previously mentioned.
Generally speaking, they are screening devices which may indicate a need for further testing. So far as their ability to predict susceptibility is concerned, Du Pont could not conclude that its use of the SAT or G-6-PD tests provided accurate or reliable predictability of hypersusceptibility.
Thus, we did not find the G-6-PD or SAT tests useful in an occupational setting and, therefore, we no longer do them. Rather than rely on such screens, we believe well-established medical tests, combined with periodic physical examinations, provide us more reliable information on whether or not an employee may be safely placed in a particular job.
In the fourth question, you ask if the workplace should be altered to eliminate the potential hazard to high-risk groups, what costs would be involved to do this, and if screening is used as a substitute for improvement in workplace quality.
As I mentioned previously, the Du Pont Co. does not exclude individuals as a substitute for achieving safe exposure levels. If individuals are adversely affected by the chemical exposure in their jobs, Du Pont will investigate the situation and then implement appropriate engineering controls, work practices, personal protective equipment or a combination of all these changes as necessary to eliminate the exposure.
The type of controls implemented are balanced according to the best control methods for the hazard, the number of individuals affected, the type of effects and the feasibility of the controls. There are situations where, as a last resort, it may be necessary to exclude individuals or a group from a particular work area.
There are also instances where some employees are more sensitive to certain chemical exposures than are others. If that sensitivity creates a health risk to the employee, and workplace controls are not feasible, we will provide employment in another area without loss of pay or employment rights, if at all possible. Thus, at Du Pont we do not substitute medical testing and removal for improvements in workplace quality.
Your remaining questions ask whether workers should be permitted to assume the risks involved in their job.
An employer, in our opinion, has the responsibility to provide a safe and healthful workplace. Du Pont does not permit workers to assume the risks of bodily harm from known or predictable hazards of occupational disease or accident.
This is the case regardless of any potential financial loss incurred by the company or the employee. If we cannot manufacture a product without creating undue risks to our employees, we will not manufacture it at all. We will not knowingly allow our employees to work at increased risk of adverse health effects due to their job.
To conclude my remarks, I would like to summarize my view of this subject. As I stated previously, Du Pont is not conducting any genetic testing other than the sickle-cell test, nor, to my knowledge, is any other company. I am aware that a very small amount of cytogenetic testing has been done, but none by Du Pont.
Where so-called genetic screening tests have been used by Du Pont, the use has been solely to determine if they have the capability to predict individuals who may be unduly sensitive to particular workplace exposures.
We are not convinced that such screening offers a benefit over existing programs in which we employ well-established medical tests. The number of chemicals which present a problem for hypersusceptible individuals is small. The few workers who have been identified as hypersusceptible can generally be offered alternative and equivalent job assignments.
Thus, any potential adverse impact from chemical hypersusceptibility is neither significant nor widespread.
I would like to add at this point in my oral statement, Mr. Chairman, that with respect to the reproductive hazards, I concur with your statement to the previous witnesses that in-utero exposure of the fetus is of much more concern to occupational physicians than is the preconception exposure of the adult male or adult female.
Mr. GORE. Let me interrupt you there and say that that was a question rather than a-intended to be a question rather than a statement, of an exploratory nature, seeking corrections of any misconceptions that it might contain.
I don't feel qualified to make that conclusion. I had that preconception at the time I posed that query. I am not sure I still have it after listening to the panel of witnesses. I believe the uncertainties involved are substantial and that there are other reasons to question that preconception.
But we can talk about that after you complete your statement.
Dr. KARRH. Let me conclude by saying that protecting the reproductive apparatus of the adult male or adult female is done in exactly the same way and we would protect any other physiological function of the adult male or adult female worker in the same manner.
We set our workplace exposure levels for what is potentially the most toxic hazard and what would be the most sensitive organ system of the employee. However, we do have difficulty when we have a fetus which is in the workplace as a third party and we either don't know that it is there, we don't have data to indicate what the risks are, or we have data but we have not been able to set an acceptable exposure level for the fetus.
But our means for protecting, whether it is reproductive apparatus at risk, respiratory apparatus, or cardiovascular apparatus, would be the same. The management of Du Pont has always been committed to leadership in employee health and safety protection programs and we intend to continue that commitment.
I wish to thank you for the opportunity to present testimony and will try to answer any questions.
[The prepared statement of Dr. Karrh follows:
PREPARED STATEMENT OF B. W. KARRH I am Dr. Bruce W. Karrh, Corporate Medical Director of the Du Pont Company. Prior to becoming medical director, I was a military physician for three years and then engaged in the private practice of medicine in Alabama for five years. I was employed by Du Pont in 1970 as plant physician at our Richmond, Virginia, location for almost three years. In that job, I performed all the tasks generally assigned to a Du Pont Company plant physician. These included conducting preemployment and routine physical examinations of employees, advising employees and management regarding health-related issues, and carrying out any special medical surveillance programs required by law or recommended by the Corporate Medical Division. In 1973, I was transferred to Du Pont's Haskell Laboratory for Toxicology and Industrial Medicine as Research Manager in Environmental Sciences, with responsibility for industrial hygiene and physiological evaluations. Following my work at Haskell, I was named Assistant Corporate Medical Director in 1974 and held this position for three years before occupying my present assignment in 1977. As corporate Medical Director, I am administrator of the Du Pont Company's occupational medical program and am responsible for developing and assisting in implementing corporate policy related to employee health matters. My office also has responsibility for consultation with and assistance to plant physicians and managers on health matters.
According to the letter inviting me to testify here today, the Subcommittee is interested in evaluating “the scientific legitimacy and legality of medical and genetic screening programs in the workplace” and whether current practices are sufficient to protect workers against "invidious discrimination on the basis of some physical trait”. I have also been asked to direct my testimony to a number of questions relevant to these topics. Before testifying on these matters, I would like to review generally some of the pertinent Du Pont Company policies.
First, it is Du Pont Company policy to provide a safe and healthful workplace for its employees. The Company does not exclude certain individuals from job assignments as a substitute for achieving safe exposure levels for its employees.
With the exception of sickle cell trait tests, the Du Pont Company is not conducting genetic screening of its employees, and I am not aware of any other company which is.
Du Pont does not conduct any cytogenetic surveillance of its employees.
Since 1972, Du Pont has been testing Black employees and Black job applicants for the sickle-cell trait. Du Pont Company does not use sickle-cell blood tests to screen for employment, job placement or promotion. The Company promotion, then assessment of that person's susceptibility to particular workplace exposures should be based on criteria which are sound scientifically and judiciously applied.
the concern is legitimate and one with which I whole heartedly concur, but it has been prompted by a mispreception of current industrial medical practices. To the best of my knowledge and contrary to the Subcommittee's assumption, industry is not conducting any genetic testing, let alone a substantial amount. Though genetic tests may be useful in a research setting, their utility in occupational medicine has not been demonstrated. Thus, aside from any ethical or policy questions they raise, they are simply not practical diagnostic tools. Instead, occupational physicians use the same standard, well established medical test employed by private practitioners serving the general public. The only exceptions to this are certain biological monitoring tests which are used to assure that workers with potential for exposure to certain harmful substances are not assimilating these into their systems.
To put industrial health programs in the proper perspective, I think it would be helpful to describe Du Pont's occupational health program to you and explain the role that employee medical data plays.
Our program is comprehensive. There are four principal components of it, which include:
(1) Toxicology: Forty-six years ago, Du Pont established the Haskell Laboratory for Toxicology and Industrial Medicine to study the toxicity of chemicals the Company uses, makes or sells. Haskell now studies about 300 substances a year to determine if they may be hazardous from an occupational or environmental standpoint. The Haskell Laboratory is equipped to study both acute and chronic hazards, and its battery of available tests allows us to assess a chemical's potential for causing mutagenic, teratogenic or carcinogenic effects. Haskell’s findings are a critical factor in management's decisions on whether or not to produce a compound.
(2) Industrial hygiene: Besides obtaining toxicity data, Haskell Laboratory recommends appropriate industrial hygiene practices and controls for use at our plant sites. Du Pont's Safety and Fire Protection Division and its Engineering Services