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Division assist in the development and implementation of these protective meas
(3) Occupational medicine: Du Pont has approximately 70 full-time and 50 parttime physicians and 200 registered nurses. The occupational physicians' job is to assure that an employee or prospective employee can safely perform the job to which he or she is assigned. In this connection, they (1) conduct pre-employment physical examinations, (2) periodically re-evaluate the employee to detect signs of adverse health effects which could be due to the job or which may increase the risk from working the job, (3) treat any work-related illness or injury and (4) assist the employee with his or her personal health care and health planning.
(4) Epidemiology: Since 1956, the Medical Division has collected epidemiological data on the causes of diseases or deaths among our employees and deaths among pensioners. These studies have been an important part of Du Pont's program to control hazards. Our epidemiologists analyze selected illness and death rate data periodically to determine whether an excessive incidence of a disease has occurred at a Du Pont site. Additionally, they conduct studies of groups of employees who have had exposure to specific potential occupational hazards in order to identify any adverse effects on health, and to determine if existing safety procedures have been effective. Our studies have confirmed that the incidence of
ancer among Du Pont employees is approximately 80 percent of that of the general population. We believe that analysis by epidemiologic technique is a good measure of the effectiveness of our occupational health programs. Such technique is also useful in detecting potential adverse effects, not only from chemical exposures, but life style, stress and other factors that might not otherwise be predicted.
To clarify our testing practices further, let me describe more fully the occupational medical component of our health program. As I stated previously, each job applicant receives a pre-employment physical examination. The examination itself is essentially the same type physical routinely given in private medical practice. It includes a comprehensive medical history, a series of blood tests, such as a complete blood count and various blood chemistry analyses, EKG, chest X-ray, pulmonary function test, eye and hearing examinations, and a physical exam. Management receives a recommendation from the examining physician about the employee's overall ability to handle a particular job safely. For example, if the individual has a history of cardiac disease or back problems, he would not be assigned to a job where he would be required to do a lot of lifting. Similarly, an employee with a history of epilepsy would not be assigned a job driving a vehicle.
After an employee has been assigned to a particular job, he or she will receive a follow-up medical examination. Employees over 40 years of age are re-examined annually; those 40 and under, biennially. The follow-up physicals are compared to the pre-employment “baseline” examination, and if there are any significant changes in the individual's health, he is informed. If he is experiencing a health problem because of his job assignment, we take whatever corrective measures are necessary. Our efforts are preventive-discover the situation before it becomes a problem-then eliminate or control it.
A key feature of our medical program is biological monitoring. DMF (dimethylformamide) and DMAC (dimethylacetamide) are two good examples of chemicals where we conduct biological surveillance. Both chemicals are readily absorbed through the skin. Because of this, we have implemented stringent engineering and work practice controls and have an ongoing and extensive air monitoring program. As a backup to these tight controls, we conduct blood tests to assess liver function and urine metabolite tests to monitor each individual to determine whether or not the substance has been assimilated. These measures are precautionary—again, their purpose is to detect a potential exposure situation well before it becomes a problem. If we discover that there has been bodily uptake of a substance being monitored, we re-examine our control measures and take corrective action.
As you can see from the description of our medical program, we use standard or specialized medical monitoring tests to assess the health of our employees-not genetic screening. Unfortunately, however, a great deal of attention was focused on Du Pont and genetic testing by a front-page New York Times article which appeared over a year ago. The article wrongly implied that Du Pont used sickle-cell blood tests to screen Blacks and that the results of these tests figured in employment decisions.
As I have already stated, this implication is absolutely false.
The Times misunderstanding was apparently precipitated by a misreading of one. sentence from an article in the Journal of Occupational Medicine by Dr. Charles F. Reinhardt, Director of Du Pont's Haskell Laboratory for Toxicology and Industrial Medicine. Dr. Reinhardt's article discussed chemical hypersusceptibility, geneticallycaused blood disorders, and how medical tests might permit detection of individuals with blood disorders that could subject them to increased risk of harm if they were exposed to cyanogenic compounds. The sentence is question deals with a hemoglobin test, a standard blood test. No one with a low hemoglobin is assigned to areas of potential exposure to cyanogenic compounds, and Du Pont's benchmark for restricting someone from work with these chemicals is a hemoglobin of less than 14 g/100 ml of blood.
In keeping with his subject of genetic blood disorders, Dr. Reinhardt's article contained a sentence stating that individuals with the sickle-cell trait who had a hemoglobin below 14 g/100 ml of blood would not be permitted to work with nitro and amino compounds. Focusing on this statement, the Times' article implied a wholesale policy of excluding Black workers or limiting their assignments and promotions, which is not the case at all. If there remains any misapprehension from this article or any other source, let me set the record straight: Sickle-cell testing is not and never has been a factor in the hiring, placement, or promotion of Black employees. As stated earlier, these tests are performed solely as a personal service for our Black employees and play no role in hiring or job placement decisions. At Du Pont, if it is necessary to restrict an individual from working with nitro and amino compounds, that decision is based on factors such as the individual's hemoglobin, any history of cardiac disease, pulmonary function tests and the likelihood that an inadvertent excess exposure could occur.
In addition to the discussion of sickle-cell testing, Dr. Reinhardt's paper and the New York Times' article mention use of two other tests, the serum anti-trypsin deficiency (SAT) and the glucose-6-phosphate dehydrogenase (G-6-PD). The SAT is an enzyme test to measure the level of serum anti-trypsin in blood. In theory, if levels are low, it indicates a genetic deficiency and a potential for developing emphysema or chronic bronchitis. Similarly, the G-6-PD is an enzyme test to determine the levels of glucose-6-phosphate dehydrogenase in the blood. If the levels are low, then an individual may have an increased risk of hemolytic reaction and inadequate oxygen-carrying capacity when exposed to industrial amino and nitro compounds.
As I mentioned previously, apart from the sickle cell testing, Du Pont does not conduct any genetic testing. Previously, however, Du Pont used the SAT and the G6-PD on a limited basis to determine whether they would be of value in protecting the health of susceptible employees. Use of the SAT was solely as a pilot project to see if it was a good predictive tool for discovering individuals who may subsequently develop pulmonary diseases. Use of the G-6-PD was also initiated primarily to assess its predictive capabilities. As is evident from this summary of our activity, Du Pont has had very limited experience with genetic testing.
I would like now to shift from Du Pont's experience to the questions asked of me by Congressman Gore. There are six of these; the first three ask: (1) Whether existing genetic tests are accurate; (2) whether they are appropriately predictive; and (3) what level of predictability from these tests is desired?
I am not an expert on the scientific methodology used to develop these tests nor on their general applicability. I am, however, familiar with their utility in an occupational medical setting. Generally speaking, these tests do just what their name implies—they are “screening” devices which may indicate a need for further testing. So far as their accuracy and ability to predict susceptibility is concerned, Du Pont could not draw any conclusions from its use of the SAT or G-6-PD tests and did not try to draw conclusions from the sickle-cell testing. Not enough testing was done with the SAT to provide a data base and the G-6-PD did not give us any additional information beyond what we had already learned from other standard medical tests. As a general matter, we have not found the G-6-PD or SAT tests useful in an occupational setting and prefer instead to rely on routine medical tests. We believe these well established medical tests, combined with periodic physical examinations, provide adequate data to ascertain whether an employee may be safely placed in a particular job.
Question four asks whether the workplace should be altered to eliminate the risk to high-risk groups. It further questions what costs would be involved to do this and whether screening is used as a substitute for improvement in workplace quality.
As I mentioned previously, it is Du Pont Company policy to provide a safe and healthful workplace for its employees. The Company does not exclude certain individuals as a substitute for achieving safe exposure levels for its employees. If a significant number of individuals were affected by the chemical exposure in their job, Du Pont would first investigate the situation and then implement the appropriate engineering controls. If these were not feasible, we would assess whether work practices or personal protective equipment could eliminate the problem or whether a combination of all of these changes is necessary. Obviously, it is in the Company's interest to solve the problem if a significant number of individuals are affected. 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. Exclusion of an individual or a group of individuals is a last resort.
There are instances, however, where some employees are more sensitive to certain chemical exposures than are others. If that sensitivity creates a health risk to the employee, we will provide employment in another area without loss of pay or employment rights if at all possible. It is rare, though, to find large groups of people who have a sensitivity to a particular chemical. Sensitivity is usually confined to one or two individuals.
Questions five and six both ask whether workers should be permitted to assume the risks involved in their job.
An employer, in our opinion, cannot shirk its responsibility to provide a safe and healthful workplace by transferring this obligation to the worker. Du Pont's practice is not to permit workers to assume the risks of bodily harm from known or predictable hazards of occupational disease or accident. This 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 jobs.
To conclude my remarks, I would like to summarize my view of this topic. So far as I am aware, genetic or cytogenetic tests are not being conducted by industry. As I stated previously, Du Pont is not conducting any genetic testing nor, to my knowledge, is any other company. I am aware of only a very small amount of cytogenetic testing being done, and none of this has been conducted by Du Pont. Where socalled “genetic screening tests” have been used by Du Pont, their use has been solely to determine if they have the capability to predict which individuals might be unduly sensitive to particular workplace exposures. It has been our experience that these genetic screening tests are not sufficiently precise for occupational medical use and that standard medical tests give us more reliable information about which employees may have a problem from exposure to certain chemicals than do genetic testing. However, if genetic screening tests are developed that in our opinion will provide accurate and reliable information about an employee's potential hypersusceptibility to a substance present in the workplace and if the tests are more reliable than existing medical tests, we will, of course, seriously consider the use of such tests. Our testing programs are designed to identify individuals who need proiection from chemicals they might contact in the workplace and are not used for purposes of discrimination nor as an excuse to avoid making appropriate workplace modification to accommodate these individuals.
The number of individuals for whom exposures present a hypersusceptibility problem is extremely small. Additionally, the number of chemicals which present a problem for hypersusceptible individuals is extremely small. The workers so affected can generally be offered alternative and equivalent job assignments. Thus any potential adverse impact from chemical hypersusceptibility is not significant or widespread.
The management of the Du Pont Company has always been committed to leadership in employee health and safety protection programs. These have included pioneering toxicological testing of chemicals at Haskell Laboratory, workplace contols to prevent hazardous exposures, epidemiological studies, industrial hygiene monitoring, and regular physical examinations for all employees. We intend to continue our commitment to provide the most progressive occupational health program available in industry today.
Mr. GORE. Fine. We thank you for your statement and we appreciate your appearance here today.
On page 7 of your testimony, you mention your concern about back injuries. Yesterday, we heard a good deal of testimony about low back X-rays as predictors of back injuries.
Do you ever use back X-rays for such purposes?
Dr. KARRH. In the past, when many other industries were using back X-rays as preemployment predictor these were utilized to some extent within the Du Pont Co. They have not been utilized since the early seventies as a test.
If we have an employee who is complaining of a back problem, then the physician will decide whether or not an X-ray is indicated
for that particular situation. But back X-rays are not used routinely at all.
Mr. GORE. And not used in a preemployment context?
Mr. GORE. Your testimony states on page 7 that you give all job applicants chest X-rays. Do you give any other X-rays to all job applicants? Dr. KARRH. Not routinely, no. Just chest X-rays.
Mr. GORE. Do you include X-rays in the followup medical examinations?
Dr. KARRH. Yes.
Mr. GORE. How do you guard against reproductive hazards associated with X-rays?
Dr. KARRH. We use low-dose film and we only make chest exposures. If a female applicant or female employee has reason to think she could be pregnant, and they are asked before the X-ray exposure is made, then we will use abdominal lead aprons as gonadal shielding to avoid any exposure that could occur to the uterus or to the fetus.
Mr. GORE. Do you think that is effective?
Dr. KARRH. Yes. This is the same routine used in hospitals when routine chest X-rays are made and we follow the same procedures.
Mr. GORE. Do you provide preemployment or followup X-rays to fertile men?
Dr. KARRH. We provide the periodic physical examinations as noted in my testimony every year to employees over 40 years of age and every 2 years to employees 40 years of age and under and these are the same for male employees as for female employees.
They do include as a part of that examination a chest X-ray.
Mr. GORE. Do you worry about reproductive hazards in such instances?
Dr. KARRH. Always when you are using X-rays you have a concern about the potential effect on the reproductive apparatus. Using low-dose film, modern X-ray equipment and modern techniques makes the likelihood of that very low.
The exposure from a routine chest X-ray properly done is very low.
Mr. GORE. Do you ask men prior to X-rays whether or not they intend to parent children at any time in the near future?
Dr. KARRH. No, and we don't ask women if they intend to. We ask them before we make the X-ray exposure if they are pregnant at that time, or if they suspect they are.
Mr. GORE. We heard testimony from the last panel that X-ray exposure to the father of a child yet to be conceived may pose a greater risk to the offspring than the risk associated with X-ray exposure to the fetus in the utero. Do you have any reason to challenge that testimony?
Dr. KARRH. I have no reason to challenge it at all, and I can't speak for the previous witnesses, but I think their concern was in the low back X-rays, not in routine chest X-rays removed from the area of the low back.
Mr. GORE. No, I am talking about the immediate prior panel.
Dr. KARRH. I heard their testimony, but I was thinking that was in response to the question on low back X-rays.
Mr. GORE. I had cited the example used in yesterday's testimony. Dr. KARRH. But as I said, I cannot speak for their testimony.
Mr. GORE. What about the case of lead exposure, do you ask women if a pregnancy might be involved?
Dr. KARRH. I am not sure I understand your question, Mr. Chairman.
Mr. GORE. With respect to a company where lead exposure occurs, do you think that company should-would you recommend that such a company adopt a similar procedure to the one you use prior to X-rays?
Dr. KARRH. Lead presents a unique problem because lead is stored within the body and retained within the worker's body for relatively long periods of time. There is good evidence, most of it is human evidence from the turn of the century, very old data, that indicates that lead does have an effect on the developing embryo or fetus, if the mother has been exposed to relatively high concentrations of lead and has a body burden of lead.
Lead is one of the compounds that many companies, including my own, have a policy that women of child-bearing capability cannot work in areas in which there is potential for exposure to lead or its salts above a certain predetermined level.
Mr. GORE. On pages 7 and 8 you refer to corrective action which the company will take under certain circumstances. In one instance, you mention that such corrective action will be taken if an employee is experiencing a health problem because of his job assignment.
In another instance, you speak of urine metabolite tests and blood tests to assess liver function.
Does such corrective action include medical removal?
Dr. KARRH. It may, if it is determined that that person is experiencing some adverse health effect as a result of the job exposure.
Mr. GORE. What else might it include?
Dr. KARRH. We would correct what caused the potential excess exposure. We would also evaluate other workers who had potential exposure in that same workplace to see if they, too, were experiencing any adverse health effect and we would correct whatever the source of that exposure was, so we would no longer be exposing people to an excessive amount.
Mr. GORE. Would medical removal be the first option and attention to the causative factor, second option?
Dr. KARRH. It would be done simultaneously. We would remove the person from risk so we wouldn't be doing anything to harm his or her health while we sought the remedy to the situation.
But we would not delay remedying the situation because we had removed the person. We do not feel we could leave the person at risk of continued adverse health effects while we seek a solution to the problem that caused it in the first place.
Mr. GORE. Suppose you removed the person from the workplace, or the part of the workplace, then conducted a review of the other employees in that workplace, and the evidence did not firmly estab