Appendix — American Textile Mfrs. Institute, Inc. v. Donovan

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Nos. 79-1429 and 79-1583

IN THE

Supreme Court of the United States

OCTOBER TERM, 1980

AMERICAN TEXTILE MANUFACTURERS INSTITUTE, INC.,

ET AL., Petitioners,

V.

RAY MARSHALL, SECRETARY OF LABOR,

UNITED STATES DEPARTMENT OF LABOR, ET AL.,

Respondents.

NATIONAL COTTON COUNCIL OF AMERICA,

v, Petitioner,

RAY MARSHALL, SECRETARY OF LABOR,

UNITED STATES DEPARTMENT OF LABOR,

Respondent.

On Writs of Certiorari to the United States Court

of Appeals for the District of Columbia Circuit

JOINT APPENDIX

NEIL J. KING WADE H. MCCREE, Jr.

Counsel of Record Solicitor General

A. STEPHEN Hut, Jr. KENNETH S. GELLER

ANDREW N. VOLLMER Deputy Solicitor General

WILMER & PICKERING BARRY SULLIVAN

1666 K Street, N.W. Assistant to the Solicitor

Washington, D.C. 20006 General

(202) 872-6000 Department of Justice

Washington, D.C. 20530

(202) 633-2217

(Additional Counsel listed inside)

PETITIONS FOR WRIT OF CERTIORARI FILED MARCH 14, 1980

(No. 79-1429) AND APRIL 9, 1980 (No. 79-1583)

CERTIORARI GRANTED ON OCTOBER 6, 1980

tg

ROBERT H. BorRK

142 Huntington Street

New Haven, Connecticut 06511

GREGORY B. TOBIN

OGLETREE, DEAKINS, NASH,

SMOAK, STEWART AND

EDWARDS

First National Bank Tower

Two Peachtree Street, N.W.

Atlanta, Georgia 30383

Counsel for Petitioner

American Textile

Manufacturers Institute,

Ine.

ROBERT T. THOMPSON

GARY S. KLEIN

THOMPSON, MANN & HUTSON

The Daniel Building

Suite 2222

Greenville, S.C. 29602

Counsel for Petitioner

Milliken and Company

JOSEPH K. MADDOX, JR.

P. O. Box 5784

Spartanburg, S.C. 29304

Counsel for Petitioner

Spartan Mills

ROBERT T. THOMPSON

GARY S. KLEIN

THOMPSON, MANN & HUTSON

The Daniel Building

Suite 2222

Greenville, S.C. 29602

Counsel for Petitioner

Hermitage, Inc.

SAMUEL K. ABRAMS

BRIAN E. MORAN

BAKER & HOSTETLER

818 Connecticut Ave., N.W.

Washington, D.C. 20006

H. J. ELAM, III

NEIL W. KOONCE

Cone Mills Corporation

Greensboro, N.C. 27405

Counsel for Petitioner

Cone Mills Corporation

CARIN A. CLAUSS

Solicitor of Labor

BENJAMIN W. MINTZ

Associate Solicitor

ALLEN H. FELDMAN

DENNIS K. KADE

DIANE E. BURKLEY

JOHN A. BRYSON

Attorneys

Department of Labor

Washington, D.C. 20210

Counsel for Respondent

Secretary of Labor

GEORGE H. COHEN

Counsel of Record for

Union Respondents

ROBERT M. WEINBERG

JEREMIAH A. COLLINS

BREDHOFF, GOTTESMAN, COHEN,

CHANIN, WEINBERG &

PETRAMALO

1000 Connecticut Ave., N.W.

Washington, D.C. 20036

(202) 833-9340

Counsel for American

Federation of Labor and

Congress of Industrial

Organizations, Industrial

Union Department, AFL-

CIO and Amalgamated

Clothing & Textile Workers

Union, AFL-CIO

LAURENCE GOLD

815 16th Street, N.W.

Washington, D.C. 20006

J. ALBERT WOLL

General Counsel, AFL-CIO

815 15th Street, N.W.

Washington, D.C. 20005

ELLIOT BREDHOFF

General Counsel

Industrial Union Department,

AFL-CIO

1000 Connecticut Ave., N.W.

Washington, D.C. 20036

ARTHUR M. GOLDBERG

General! Counsel

Amalgamated Clothing &

Textile Workers Union

15 Union Square

New York, New York 10003

Of Counsel

DAN M. Byrp, Jr.

J. SPRATT WHITE

P. O. Box 70

Fort Mill, S.C. 29715

Counsel for Petitioner

Springs Mills, Inc.

ROBERT H. BoRK

142 Huntington Street

New Haven, Connecticut 06511

Counsel for Petitioner

Fieldcrest Mills, Inc.

THOMAS A. EVINS

CLYDE H. HAMILTON

BUTLER, MEANS, EVANS &

BROWNE

P. O. Box 451

Spartanburg, S.C. 29304

Counsel for Petitioner

Arkwright Mills

ROBERT T. THOMPSON

GARY S. KLEIN

THOMPSON, MANN & HUTSON

The Daniel Building

Suite 2222

Greenville, S.C. 29602

Counsel for Petitioner

Blair Mills, Inc.

HARLAN H. HUNTLEY

ROGER L. TUTTLE

2291 Memorial Drive

Danville, Virginia 24541

Counsel for Petitioner

Dan River, Ince.

THOMAS A. EVINS

CLYDE H. HAMILTON

BUTLER, MEANS, EVINS &

BROWNE

P. O. Box 451

Spartanburg, S.C. 29304

Counsel for Petitioner

Mayfair Mills

FRED M. RICHARDSON

Lovic A. BROOKS, JR.

CHARLES A. EDWARDS

CONSTANGY, Brooks & SMITH

1900 Peachtree Center Building

230 Peachtree Street, N.W.

Atlanta, Georgia 30303

Counsel for Petitioner

Riegel Textile Corporation

RICHARD H. MONK, JR.

C. POWERS DORSETT

West Point-Pepperell, Inc.

P. O. Box 71

West Point, Georgia 31833

Counsel for Petitioner

West Point-Pepperell, Inc.

CHARLES M. CRUMP

Counsel of Record

APPERSON, CRUMP, DUZANE &

“MAXWELL

2610 100 North Main Building

Memphis, Tennessee 38103

(901) 525-1711

JOSEPH A. Moss

4143 27th Street, N.

Arlington, Virginia 22207

(703) 525-4063

Counsel for Petitioner

National Cotton Council

of America

+

TABLE OF CONTENTS

Page

I. Relevant Docket Entries in the Courts of Appeals.. 1

II. Exhibits Submitted in the Proceeding Before the

FR ee NEST PCL IE TE Shey 7

1. National Institute for Occupational Safety

and Health, “Criteria for a Recommended

Standard: Occupational Exposure to Cotton

Dest” (ix. 1, emcerphed) 9

2. Roach & Schilling, “A Clinical and Environ-

mental Study of Byssinosis in the Lanca-

shire Cotton Industry” (Ex. 6-1, excerpted) ._.. 14

3. Bouhuys, “Byssinosis in the United States”

CS Ren RTL OE ME Pah a eS Teh 15

4. Braun, et al., “Prevalence of Respiratory

Signs and Symptoms Among U.S. Cotton

Textile Workers” (Ex. 6-19, excerpted) 23

5. Bouhuys, et al., “Byssinosis in Cotton Textile

Workers” (Ex. 6-24, excerpted) 24

6. Bouhuys, “Breathing, Physiology, Environ-

ment and Lung Disease” (Ex. 6-27, ex-

GE ee ee ee 25

7. Merchant, et al., “An Industrial Study of

the Biological Effects of Cotton Dust and

Cigarette Smoke Exposure” (Ex. 6-44, ex-

I Seahaatha pascal 8 aa es 27

8. Merchant, “Dose Response Studies in Cotton

Textile Workers” (Ex. 6-51) 29

9. Molyneux & Berry, “The Correlation of Cot-

ton Dust Exposure With the Prevalence of

Respiratory Symptoms” (Ex. 6-55, ex-

MRE USE RCE EL Craton MUM ERBN I” BN Seat > me 56

10. Imbus, “Experience with Medical Surveillance

Programs” (Ex. 6-57, excerpted) 58

i.

12.

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

ii

TABLE OF CONTENTS—Continued

Molyneux & Tomblesen, “An Epidemiological

Study of Respiratory Symptoms in Lancashire

Mills” (Ex. 6-66, excerpted) .............0........------

Schilling, et al., “Cardiovascular Disease in

Cotton Workers—Part I” (Ex. 6-73, ex-

IE roiglie ends cate butcstlccsccaneinica cece secdeabeesnspnedsaeiadaaSenck

Research Triangle Institute, Technological

Feasibility Assessment and Final Inflationary

Impact Statement (Ex. 6-76, excerpted) .......

Statement of Dr. Arend Bouhuys (Ex. 11,

I er eit ee hs ea es

ETRE aR, NPE TRO S ONT TK OTE EE, CPOE HERI

Weill, “Report to the American Textile Manu-

facturers’ Institute on a Study Entitled

Assessment of Respiratory Responses in Tex-

tile Workers Exposed to Low Levels of Cotton

Dust” (ix. 154, excerpted) ..................-.......

Statement of Bruce Held (Ex. 15, excerpted)..

Research Triangle Institute, “Technological

Feasibility and Economic Impact of Regula-

tions for Cotton Dust” (Ex. 16, excerpted) ....

Merchant, Memorandum to Grover C. Wrenn:

“Review of Draft Proposal for Cotton Dust

Standard” (Ex. 26, excerpted) ....00000.000..00000....

Statement of Edward J. Baier (Ex. 38a, ex-

ERTS PCR aa LIne Sere aPC

Merchant, “Epidemiological Studies of Respi-

ratory Disease Among Cotton Textile Work-

ers 1970-1973” (Ex. 38D, excerpted) .............

Morgan, et al., “Report on Survey on Preval-

ence of Byssinosis and Respiratory Symptoms

in Three Textile Mills” (Ex. 39, excerpted) ....

Page

61

151

156

157

164

167

174

175

176

179

23.

24,

25.

26.

27.

28.

29.

30.

31.

32.

33.

34,

35.

36.

iii

TABLE OF CONTENTS—Continued

Page

Supplemental Submission to Statement and

Testimony of W. K. C. Morgan, M.D. (Ex.

i IED Soctiesesisccs ceri ar Oe 183

Statement of W. K. C. Morgan, M.D. (Ex 40,

vse, sete he a RC Me Pe Re 185

Statement of Russell A. Harley, M.D. (Ex.

a er an ti EOP NRO 190

Annual Cotton Dust Survey (Ex. 48) 198

Supplemental Submission to Statement and

Testimony of Harold R. Imbus, M.D., Sc.D.

(me. 47d, Qxcerpéed) 200

Statement of M. C. Battigelli, M.D. (Ex. 48,

II ate e 203

“Burlington Industries Took Our Breath

Away” (Ex. 54, excerpted)... 208

Statement of Carolina Brown Lung Assorcia-

tion (Ex. 54a, excerpted)... 217

Statement of Moon W. Suh, Ph.D. (Ex. 55)... 221

Statement of Hovan Hocutt eee 234

Statement of L. K. Fitzgerald (Ex. 69, ex-

IE ee ie i ai aie ti xan. 252

Submission of Amalgamated Clothing and

Textile Workers Union: Vol. 1 (Ex. 78,

IN idekinsiicd etisalat. 266

Statement of Parker C. Reist and Lawrence

D. Kornreich (Ex. 79a, excerpted) ..:.............. 293

Reist, et al., “The Impact of New Production

Equipment on Control Costs to Meet the Pro-

posed Cotton Dust Standard” (Ex. 79c, ex-

sen as ise, Re TO RT CRIED 296

37.

38.

39.

40.

41.

42.

43.

44,

iv

TABLE OF CONTENTS—Continued

Page

Statement of William A. Burgess (Ex. 80a,

CID aces inscicsviesineccwicendstsinsnantacinabcene eas 309

Statement of Eric Frumin (Ex. 82, ex-

IID usscttsenicsanisicctscoi-rveieshecmanmeenaaigineiiioamase esas 316

Statement of U.S. Department of Agriculture

(ie, SGC, Ceeeteees: ..nc ee 325

Statement of John S. Barr, III (Ex. 101, ex-

1} SRNR Ne OPENER ON rt Me UREN Ee Tn NR 327

Comments of the Council on Wage and Price

Stability (Ex. 111, excerpted) .................0..... 331

Statement of Dr. Sidney Wolfe & Peter Greene

(ix. 228, GCE? Lo MPS 343

Bouhuys, et al., “Epidemiology of Chronic

Lung Disease in a Cotton Mill Community”

CHER BG, GOES bck xchat ae 344

Supplemental Submission of Amalgamated

Clothing and Textile Workers Union (Ex. 143,

CIID Siciisccetnccndncdacunsdinataneecsascieaaaea is 348

45. Post-Hearing Comment of the American Tex-

tile Manufacturers Institute, Inc. (Ex. 160,

SU iaeccinisnctisesaicsghcesccinasab biaieaatiin 372

46. Letter from F. S. Love to Eula Bingham (Ex.

EV R\ SIONS | nvisnncccinncicciateces 388

47. Statement of Arthur Thomas (Ex. 62, Attach-

a | a ae NC Be: SOMME Ce AC ae 486

III. Transcript of Hearing Before the Agency .............. 399

1. Excerpted testimony of Dr. Bouhuys .............. 401

2. Excerpted testimony of Dr. Kilburn .............. 410

3. Excerpted testimony of Dr. Weill .........000000000.. 410

4. Excerpted testimony of Mr. Held -.................. 412

5. Excerpted testimony of Dr. LeSourd ............ 414, 418

6. Excerpted testimony of Dr. Lee ~...0000.00000000.... 416

7. Excerpted testimony of Dr. El Batawi .......... 421

IV.

v

TABLE OF CONTENTS—Continued

Page

8. Excerpted testimony of Dr. Merchant....423, 435, 485

9. Excerpted testimony of Dr. Taylor... 434

10. Excerpted testimony of Dr. Baier... 442

11. Excerpted testimony of Dr. Morgan _............ 444

12. Excerpted testimony of Dr. Harley ........... 444

18. Excerpted testimony of Dr. Martin... 445

14. Excerpted testimony of Dr. Imbus ................ 445

15. Excerpted testimony of Dr. Neefus ......__. 449

16. Excerpted testimony of Ms. Norton ......... 451

17. Excerpted testimony of Ms. McCoy _.............. 452

18. Excerpted testimony of Mr. Harrell... 453

19. Excerpted testimony of Mr. Sandlin ......._. 453

20. Excerpted testimony of Mr. Hassell... 454

21. Excerpted testimony of Mr. Baldwin ......___ 455

22. Excerpted testimony of Mrs. Sanders... 456

23. Excerpted testimony of Mr. Graves _............. 457

24. Excerpted testimony of Mr. Hocutt... 458

25. Excerpted testimony of Mr. Figh _............... 473

26. Excerpted testimony of Mr. Chapman ............ 476

27. Excerpted testimony of Dr. Reist 477

28. Excerpted testimony of Prof. Burgess ............ 481

29. Excepted testimony of Mr. Davis _............... 482

30. Excerpted testimony of Mr. Mabe _................. 483

31. Excerpted testimony of Mr. Frumin .....___. 484

Order of Supreme Court granting Petitions for

Writs of Certiorari in Nos. 79-1429 and 79-1583... 487

I. Relevant Docket Entries

in

American Federation of Labor & Congress

of Industrial Organizations, et al.,

Vv.

Ray Marshall, et al.

No. 78-1562 (D.C. Cir.)

(and Consolidated Case Nos. 78-1736,

78-1979, 78-1980, 78-1981, 78-1982,

78-1983, 78-1984, 78-1986, 78-1987,

78-1988, 78-1989, 78-1990, 78-1991,

78-1992, 78-1993, 78-2013, 78-2014,

78-2016 and 78-2018)

Date

Filings, Orders, and Proceedings

1978

June 19

June 19

July 27

August 2

August 3

August 7

August 7

August 10

August 14

August 15

August 16

Filing of Petition for Review of Cotton Dust

Standard by American Federation of Labor

& Council of Industrial Organizations, et al.

(D.C. Cir.)

Filing of Petition for Review of Cotton Dust

Standard by American Textile Manufacturers

Institute, Inc. (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Milliken and Company (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Arkwright Mills (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Spartan Mills (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Blair Mills (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Hermitage, Inc. (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by West Point-Pepperell, Inc. (5th

Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Dan River, Inc. (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Cone Mills Corporation (4th

Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Nationai Cotton Council of

America (6th Cir.)

_ PREVIOUS PAGE WAS BLANK |

4

Date

Filings, Orders, and Proceedings

1978

August 16

August 16

August 17

August 18

October 3

October 6

October 7

October 13

December 15

December 15

December 15

December 15

Filing of Petition for Review of Cotton Dust

Standard by Springs Mills (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Mayfair Mills (4th Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Riegel Textile Corporation (4th

Cir.)

Filing of Petition for Review of Cotton Dust

Standard by Fieldcrest Mills, Inc. (4th Cir.)

Order transferring Cotton Dust Petitions for

Review pending in the Fourth Circuit to the

District of Columbia Circuit

Order transferring National Cotton Council

of America Petition for Review from the

Sixth Circuit to the District of Columbia

Circuit

Order transferring West Point-Pepperell, Inc.

Petition for Review from the Fifth Circuit to

the District of Columbia Circuit

Order consolidating Cotton Dust cases in the

District of Columbia Circuit

Filing of Opening Brief of Petitioners Ameri-

can Federation of Labor & Congress of In-

dustrial Organizations, et al.

Filing of Joint Brief of the American Textile

Manufacturers Institute, Inc., et al.

Filing of Supplemental Brief of Petitioner,

National Cotton Council of America

Filing of Amicus Curiae Brief of American

Farm Bureau Federation

Date

Filings, Orders, and Proceedings

1979

January 26

February 7

February 7

February 7

February 14

October 24

November 7

November 7

1980

January 11

January 11

January 16

Filing of Brief for the Secretary of Labor

Filing of Reply Brief of Petitioner National

Cotton Council of America

Filing of Reply Brief and Brief in Interven-

tion of Petitioners American Federation of

Labor & Congress of Industrial Organiza-

tions, et al.

Filing of Joint Reply Brief of the American

Textile Manufacturers Institute, Inc., et al.

Oral Argument in the United States Court of

Appeals for the District of Columbia Circuit

Entry of Judgment and Opinion of the United

States Court of Appeals for the District of

Columbia Circuit (Reprinted in the Appendix

to the Petition for Writ of Certiorari at 19)

Filing of Petition for Rehearing and Sug-

gestion for Rehearing En Banc of Petitioner,

National Cotton Council of America

Filing of Joint Petition for Rehearing and

Suggestion for Rehearing En Banc of Ameri-

can Textile Manufacturers Institute, Inc., et

al.

Order denying Petitions for Rehearing (Re-

printed in the Appendix to the Petition for

Writ for Certiorari at 103)

Order denying Suggestions for Rehearing En

Banc (Reprinted in the Appendix to the Peti-

tion for Writ of Certiorari at 104)

Motion of National Cotton Council of Ameri-

ca for Stay of Mandate

Date

Filings, Orders, and Proceedings

1980

January 16

January 17

January 17

January 22

March 14

April 9

October 6

Filing of Joint Motion for Stay of Mandate

by the American Textile Manufacturers Insti-

tute, Inc., et al.

Filing of Opposition to Motions for Stay of

Mandate by the Secretary of Labor

Filing of Response of Union Petitioners to

Motions for Stay of Mandate

Order directing clerk to issue mandate (Re-

printed in the Appendix to the Petition for

Writ of Certiorari at 106)

Filing of Petition for a Writ of Certiorari by

Petitioners American Textile Manufacturers

Institute, Inc., et al.

Filing of Petition for a Writ of Certiorari by

Petitioner National Cotton Council of America

Entry of Order granting Petitions for Writs

of Certiorari (Reprinted in this Joint Ap-

pendix at 489)

II. EXHIBITS SUBMITTED IN THE PROCEEDINGS

BEFORE THE AGENCY

9

EXHIBIT 1

National Institute for Occupational Safety and Health,

“Criteria for a Recommended Standard: Occupational

Exposure to Cotton Dust”

Feasibility of Control

Control of dust levels in cotton-processing operations

can be achieved by changing or treating the raw mate-

rial which is the source of the dust, by changing the

process which produces the dust, or by removing the

dust from the air once it is generated.

The transition from natural to synthetic fibers in the

past decade has resulted in lower byssinosis-producing

dust levels in those mills using synthetics or blends. Mer-

chant et al [18] reported a median dust level of 0.485

mg/cu m for 493 samples collected in mills working with

pure cotton and a median dust level of 0.163 mg/cu m

for 237 samples collected from mills using blends of nat-

ural and synthetic fibers. The synthetic fibers are vir-

tually trash free and thus contribute little to the total

sample collected. [136] It would be expected that, as the

synthetic content of the raw material increased, the dust

levels in most work areas would decrease.

A second method of changing the raw material is

through the improvement of growing techniques to reduce

the trash content of the cotton. Approaches such as de-

veloping cotton varieties which shed their bracts prior to

maturation and harvest or the development of dwarf

determinant cottons with increased fruiting potential

compared to the production of vegetative parts [137]

offer future potential methods of dust control, but at

present these approaches are not feasible. There is little

doubt that exposure to cotton dust trash has been greatly

augmented by the replacement of handpicking by ma-

chines. [138] Studies are in progress to find new chem-

_ PREVIOUS PAGE WAS BLANK |

‘ 5

10

icals which will more efficiently defoliate cotton and re-

duce the trash content of the harvested seed cotton. [137]

A third method of changing the raw material is by

steaming. Studies of this technique indicated that steam-

ing could reduce the toxic effect of the cotton dust with-

out rendering the cotton unsuitable for processing. [94]

Some investigators conclude that the byssinosis-producing

dusts are not removed or detoxified, but are just made to

adhere more firmly to the cotton fibers; therefore the

byssinosis problem is not solved but only moved from the

opening, picking, and carding areas to the winding and

weaving operations. [139] However, recent studies in a

cotton spinning plant do not show an increase in down-

stream dust levels when processing steamed cotton. [140]

Thus, while steaming may not be at this time a feasible

alternative to dust control, it may become effective as a

supplementary control method after further development.

[140] Work is also in progress on improved ginning

methods to allow for more efficient trash separation

and/or fractionation. [137]

There appears to be little that can be done now to

change the process in which cotton fibers are formed

into yarn and woven into cloth in order to control dust

production. The cotton manufacturing process is essen-

tially one of fiber cleaning and alignment with the de

sired goal of removing all material in the cotton except

the mature fibers. The dust in the cotton is thus an

unwanted byproduct which must be dealt with. It is

possible that the ginning process could be changed, and

work is being actively pursued along these lines [137];

but at present process change does not appear to be a

feasible alternative to dust control.

There are also a number of environmental factors

which can be adjusted to some extent to control dust

levels. As the opening and cotton cleaning machinery

more efficiently removes trash and dust from the cotton

11

stock, the release of this material into the work areas

diminishes. Thus, dust levels in the picking room, card-

room, and subsequent operations can be reduced by better

cleaning of the cotton in the opening and cleaning line.

[141]

Decreasing the production machine density in a work

area should decrease the dust levels in that area also.

Conversely, if the machines are crowded together, higher

dust levels would be expected. Dust emission is also

increased by higher card speeds. Improperly or poorly

maintained production machinery can also lead to higher

dust levels. Hocutt [141] reports that cardroom dust

levels are lower when the cards are well maintained and

properly operated with alert operating personnel using

precise machine settings.

Large central air-conditioning systems will tend to

even out dust concentrations over the entire mill. [141]

Of course, this might create new problems instead of

getting rid of one, since it would cause increased dust

level in some area while decreasing those in others. How-

ever, air-conditioning a textile mill does provide some

dust control, but the control is incidental and the in-

creased dust load in the air-conditioning unit will result

in increased maintenance costs and impede the perform-

ance of the air conditioner. Dust is removed by the

washer, a unit which acts as the primary humidifier and

heat exchanger in the air-conditioning system. The

washer is about 25% efficient for large particles [141]

and much less efficient for smaller ones. Reliance on the

air conditioner for dust control means that the dust must

travel through the work area to reach the air-conditioner

inlet, usually located on one wall of the room. Thus, the

very nature of the system makes it inefficient for dust

reduction or removal.

The capture and removal of dust from the air after it

has been generated from the cotton represents the most

12

widespread and efficient method of dust control at the

present time. Table IV-3 gives summarized results from

a study conducted recently by Barr et al [127] on the

effectiveness of dust controls in mills having different

degrees of dust control and processing varying grades of

cotton. These results serve only to indicate the ranges of

concentrations which may be expected for the different

operations, with and without dust controls.

It appears that in some instances there may be dust

concentrations (<0.5 mg/cu m) near cotton processing

operations without dust control devices, but this would be

the exception rather than the rule.

TABLE IV-3

RANGE OF TYPICAL LINT AND DUST CONCENTRATIONS

Total Dust excluding lint

Operation (mg/cu m) (mg/cu m)*

Picking, no control -— 0.6-1.6

Picking, control 0.4-0.7 0.3-0.4

Opening and picking, no control 1.5-9.1 0.2-1.9

Opening and picking, control —_ 0.3-0.5

Carding, no control §.2-21.2 0.3-5.4

Carding, control 0.5-8.4 0.1-4.2

* As measured by the vertical elutriator from reference 127.

In a study of four cards, Wood and Roach [11] found

dust removal to be less effective than indicated in Table

IV-3; total dust levels ranged from 4.2-5.8 mg/cu m

without dust extraction to 1.3-4.8 mg/cu m with dust

extraction.

Efficient dust removal in cotton processing areas de-

pends on two factors. First, there must be effective dust-

capturing devices located at the points where dust could

be generated. The captured dust is then transported

away from the point of generation to a point where it

13

can either be discharged to the outside atmosphere or re-

moved by some means from the carrier air stream. Direct

discharge of the captured dust to the ouside atmosphere

is not practical for two reasons. The dust is emitted in

sufficient quantity to quickly produce its own air pollu-

tion problem outside, and some will probably find its way

back into the work area negating the effect of the dust

capture mechanisms. A second and often more compelling

reason for not directly discharging into the atmosphere

is the loss of conditioned air which must. be replaced by

new, heated or cooled makeup air. The quantities of air

required for effective dust capture are large enough so

that the usual practice is to recycle this air volume within

the mill. [127]

Air which receives dust at one point and is cleaned at

another point during complete recirculation will with

time reach an equilibrium dust concentration. With ideal

mixing, this concentration will equal the cleaned air dust

concentration plus the ratio of the dust production rate

divided by the recirculated air flow rate. [127] With

good dust capture (low ¢ .st production rate) or a large

recirculating air flow rate the concentration of dust in

the air which is returned to the workroom will eventually

determine the concentration of dust in that space. The

isolation of dusty operations, successful in controlling

dust exposures in other industries, has not been widely

adopted in cotton mills.

& * * * on

14

EXHIBIT 6-1

Roach & Schilling, “A Clinical and Environmental Study of

Byssinosis in the Lancashire Cotton Industry.”

Our suggested grading of workrooms according to dus-

tiness was arrived at after consideration of the preva-

lence in groups exposed to similar concentrations for sim-

ilar lengths of time. We might have deduced permissible

levels of dustiness from dose response curves in a similar

way to that suggested by Roach (1953). However, we

were hesitant to do this because of the possible effects of

selection in those groups with the highest prevalence of

byssinosis. People with byssinosis are generally aware

that the dust affects their breathing and it is likely that

they will leave their jobs more readily than those who are

not so affected. To this extent the people working in a

cotton mill are likely to be a selected population, particu-

larly those groups who work in the dustiest jobs and are

in consequence affected most by dust. To deduce permis-

sible levels of dustiness from dose-response relationships

we would have had to assume that selection operates in

an exactly similar way in all mills or does not operate

at all.

* * + ” *

15

EXHIBIT 6-16

BYSSINOSIS IN THE UNITED STATES

Dr. Arend Bouhuys

J.B. Pierce Foundation Laboratory

Yale University School of Medicine

New Haven, Conn.

I would like to discuss some of the main points con-

cerning the definition of byssinosis. At risk are cotton,

flax, and hemp workers in carding and other types of

dusty work. The symptoms of the disease are chest tight-

ness, cough, and wheezing. The peculiar property of

these symptoms is the timing of their occurrence. In the

first few years of exposure, symptoms occur on Mon-

day, or other days after absence from the work en-

vironment; later, symptoms occur on other days of the

week; and eventually, symptoms are continuous, even in

the absence of dust exposure. This description constitutes

a definition of byssinosis, which many of my colleagues

and I adhere to. That is, byssinosis is a disease which

starts with short lasting acute responses to dust ex-

posure and may progress to chronic lung disease with

more or less severe disability. There has been disagree

ment on the use of the term byssinosis. Some would want

to limit the diagnosis to persons who have evidence of

chronic lung impairment only. This, however, would de-

tract from the urgent need to prevent the development

of chronic lung disease, and we must focus an important

part of our effort on those people who respond acutely

to dust but who do not yet have irreversible lung

damage.

This condition has been observed all over the world.

In Belgium it was studied in some 2,000 cotton workers

and was described as Monday chest tightness in the year

1845. I might add that already in 1837 a young New

York physician, McCready, wrote a book on occupational

16

disease, and in it he made the remark that the New

England cotton mills should do something about the dust

in the workrooms. However, he did not elaborate on the

reasons why he thought that this dust should be removed

from the air.

The disease has been studied on all continents except

Latin America. So far it ranges from Dr. Gandevia in

Australia (who is here today), Dr. Shogo Shima in Japan,

and others in India, Taiwan, and a number of African

countries, several European countries, and to the United

States and Mexico. In nearly all of these studies, a

smaller or larger number of people have been diagnosed

as having byssinosis. Many physicians have been in-

volved in these studies and their results have been re-

markably similar. In most of these countries the disease

was identified in the industry by epidemiologists. It is

a recurring pattern, whenever this disease occurs, that

physicians in hospitals and clinics underestimate the

prevalence of this disease.

The prevalence of byssinosis in the United States,

studied in three mills, has been found to be rather similar

in that some 20% to 30% of the people in the carding

room are affected. The percentages of people in the

spinning rooms vary more. There are technical reasons

for this, but I won’t go into these at this time. Two

main points I want to make about these findings. In

the first place I want to draw your attention to a mill

in the Atlanta Federal Penitentiary, where some 100 men

were exposed to dust for less than one year. Percentage

prevalence of Monday symptoms of byssinosis was similar

in that category and in the total numbers of workers.

The total number of these workers, the duration of ex-

posure to the dust, the number of years that people had

worked in this environment was much less than in the

two commercial mills, where people had on the average

worked for 12 to 18 years. In all these areas the total

17

dust concentration, in milligrams per cubic meter, is not

excessively high compared to what has been found in

earlier studies. This is very likely related, at least in

part, to what Richard Schilling has already shown you

about the effect of lint removal from the air. In all

these mills there were some systems to abate dust and

it is likely that these machines did a rather good job in

cleaning out the visible coarse dust that does not get

into your lungs, but left in the air the invisible small

dust that does get into your lungs. I should remind you

that about the best air filters for small dust particles

are our own lungs; they have so many very fine tubes

where the circumstances for deposition of particles, less

than 5 u in diameter, are really very excellent and these

are much better filters than any of the mechanical de-

vices that are currently used in most textile mills.

How can we detect this disease apart from asking the

workers for their symptoms? One of the best ways of

doing this is by having the worker blow hard into a

spirometer, a measuring device for lung volume changes,

before he starts work on a Monday and again before he

goes home at the end of the shift. At the end of the

Monday the value measured by this device [the forced

expiratory volume in 1 second (FEV 1)] is lower than

in the morning. The results of a group of cotton workers

in Sweden provide data similar to that obtained in many

cotton mills including those in this country. At the end

of the day on Monday these people, on the average, have

significantly lower values of their capacity to breathe out

forcefully, and this decrease is larger in those who com-

plain of Monday symptoms than in those who do not

have such a history. This change means that somewhere

along the airways there is some narrowing of the fine

tubes that conduct the air to our lungs. The people who

do not. complain have a similar response as those who

do. In other occupations, including coal mining and

other dusty jobs, such a response does not occur. The

18

people in coal mining and other dusty jobs do not de-

crease their FEV 1 during exposure and likewise people

in other occupations do not show such a response.

The decrease of FEV 1 in textile workers is caused by

the dust they inhale. Those with the more severe drop

of FEV 1 will complain of chest tightness; those with

less severe responses may not complain.

Another way of looking at the same phenomenon is

provided by the flow-volume curve. These are curves

which I will interpret very simply by saying that the

horizontal axis shows how much you can breathe out.

The length of the horizontal portion of the curve is

proportional to the volume one breathes out. The dis-

tance along the ordinate is proportional to how fast you

can breathe it out. In other words, you have a sort of

performance diagram of the lungs during expiration.

Without going into the physiology of it, I would just

like to state that the rapidity of expiration in a con-

siderable proportion of this curve is quite unrelated to

how hard you try. You have to deliver a minimum of

effort but beyond that you will not improve the flow

rates. These flow rates decrease markedly by the end

of the work shift. An example is given, based on results

in six representative workers. These flow rate decreases

are caused by the narrowing of small airways in the

lungs.

Let me describe two older textile workers. These men

have been exposed to hemp dust for about 25 years or

more and it illustrates what can happen. Two things

can happen to someone who stays in this dust long

enough. On the one hand, we have a man of 58 years

who has a normal pulmonary function. His vital ca-

pacity is normal for his age and height. His flow rates

are also normal for his age and height. This person

has never experienced Monday symptoms of byssinosis

while he worked in the dust. Unfortunately, such people

19

are in the minority. The other man is 59 years of age.

His pulmonary function is severely decreased. His vital

capacity is far too small, but much more important, his

capacity to breathe out rapidly is severely disturbed.

As a result this person is severely disabled. This man

has experienced Monday Symptoms of byssinosis al]

through his working life. Unfortunately, such people

form a much larger proportion of an older population of

these workers than do the non-reactors of which the first

man is an example. There are many disabled cotton

workers in the southern part of the United States. In

1966 Dr. Schilling and I spent altogether one week in

the South and, with the aid of two physicians, we saw

14 cotton workers. Half of these were severely disabled

by respiratory deficiency. I’m convinced that a more

thorough and more systematic study would show this

type of disability is prevalent wherever appreciable num-

bers of people have been exposed to cotton dust for

many years. We have not yet been able to do such a

thorough epidemiological study in the United States, but

we have done this in Spain in a town where a large

proportion of the population used to work in hemp dust.

Hemp workers and controls do not differ in the younger

age category. The difference is highly significant in the

older category where the hemp workers have a severely

decreased FEV 1, which is quite significantly smaller

than that in the control subjects who were living in the

Same area but who were not exposed to the dust. I might

say that these control subjects are quite comparable in

this respect to the data which has been obtained by sev-

eral people in other populations, like Dr. Ferris in British

Columbia. This type of data is pretty much the same

wherever you do it unless there is some special factor at

work, like in this case the hemp dust.

It has been asked, of course, what is the agent in the

dust that causes this acute response which may lead in

20

a certain portion of cases to severe chronic lung disease.

The bracts are the crumbling leaves around the stem

that are dead long before the plant is harvested. When

we make a very simple watery extract of these bracts,

we can demonstrate certain effects on human lung tissue.

In the laboratory we can also have this extract inhaled

by healthy people. Two healthy investigators inhaled

this extract of bracts for ten minutes. In this case we

had boiled the bracts to determine whether or not the

agent was heat stable. Both the subjects experienced

chest tightness after this exposure. Both of them have

a decrease of maximum flow rates—very similar to what

one finds in the cotton and hemp workers exposed to the

industrial dust. We believe that there is a pharmacologi-

cal agent which is in the dust because the dust contains

bract particles, broken up. A substance that is rather

easily water-soluble, so that when dust hits your air-

ways, this substance can transfer to the tissue and exert

its toxic action. Whether this agent is the sole cause of

the long term changes remains to be seen. It is also quite

possible that apart from the one action of this agent,

which we have identified, there are others which con-

tribute to an action. So far, however, we have been unable

to get similar data with any other part of the cotton

plant we’ve tried, so for practical purposes I think that

these leaves are very important. If they were not in the

cotton dust we would very likely have much less of a

problem. Control of this disease is obviously necessary

and I’m sure that this is going to be mentioned by several

speakers in this program and I don’t want to preempt

what they are going to say. I would like to emphasize,

I think there are many good measures that can be taken

on relatively short term at least to prevent poeple who

are now at work in the industry from becoming dis-

abled and those who may have some degree of irrever-

sible decrease of pulmonary function from getting worse.

I think this can be achieved by education, by pre-employ-

21

ment medical examination, and by periodical medical

examinations. There are a number of common sense

measures that can be taken to protect people who are

in the industry. I’m sure that some people who are

affected might be transferred to other jobs. This is not

practical forall of them, obviously, and it is not prac-

tical for all of those who respond to dust. Also, there

are drugs that can prevent the acute action of this dust,

which might be used in suitable cases. On the long

term, there is no substitute for suppression of the fine

dust; in the air. This is a very urgent matter, as Richard

Schilling has also pointed out. Technology will have to

be developed for getting rid of the fine dust which, so

far as I am aware, has not been done in the textile in-

dustry on any large scale.

I think that a large amount of work has to be done,

not only in this particular industrial lung disease, but

in general in industrial lung diseases. My personal

feeling and that of several of my colleagues is that as

a cause of environmentally induced lung disease, indus-

trial emissions are far more important than general air

pollution as a cause of disability and death. They can

be completely prevented and we don’t have to wait for

much further research in order to prevent the diseases.

There is a lot that remains to be learned ehout. these

diseases, but there is also a serious lack of application

of the knowledge that we have and we don’t have to wait

until all the answers are in before we can prevent people

from becoming disabled by industrial lung disease.

The data on which this presentation is based has been

published in the following papers:

Bouhuys, A., L. J. Heaphy, Jr., R. S. F. Schilling,

and J. W. Wellborn. 1967. Byssinosis in the United

States. New Eng. J. Med. 277:170-175.

ne ee

22

Bouhuys, A., R. L. Wolfson, D. W. Horner, J. D.

Brain, and E. Zuskin. 1969. Byssinosis in cotton

textile workers. Respiratory survey of a mill with

rapid labor turnover. Annals Int. Med. 71 :257-269.

Zuskin, E., R. L. Wolfson, G. Harpel, J. W. Well-

born, and A. Bouhuys. 1969. Byssinosis in carding

and spinning workers: Prevalence in the cotton

textile industry. Arch. Environ. Health, 19 :666-

673

The prevention and control of byssinosis and of indus-

trial lung diseases have been discussed in:

Bouhuys, A. and J. M. Peters. 1970. Control of en-

vironmental lung disease. New Eng. J. Med. 283:

573-582

Bouhuys, A., J. C. Gilson, and R. S. F. Schilling.

1970. Byssinosis in the textile industry; research,

prevention and control. Arch. Environ. Health 21:

475-478.

23

EXHIBIT 6-19

Braun, et al., “Prevalence of Respiratory Signs and

Symptoms Among U.S. Cotton Textile Workers”

* * « * &

The workers who complain of tightness do not neces-

sarily have a loss in FEV,.., or vice versa, as stated in

the literature.

* * = e *

‘ad

24

EXHIBIT 6-24

Bouhuys, et al., “Byssinosis in Cotton Textile Workers”

* - * * .

No general agreement has as yet been reached on

these questions. Our tentative answer to the first ques-

tion is affirmative: If lung function tests show that air-

way obstruction develops in a worker during textile dust

exposure, we view this as objective evidence that the dust

affects his airways. For several reasons such persons

ray not always mention subjective symptoms of res-

miratory distress during a questionnaire interview. When

interviewed on Monday after work, symptoms may be

mentioned by men who denied them during a previous

interview conducted at a time that they did not experi-

ence the dust effect (22). Secondly, some textile workers

markedly dissimulate symptoms (28), possibly because

of fear of losing their job. Thirdly, as in other diseases,

the threshold of awareness of distress may vary indi-

vidually. We believe that byssinosis should be diagnosed

in all workers in whom evidence of an effect of textile

dust on the lungs is obtained.

* * a * *

25

EXHIBIT 6-27

Bouhuys, “Breathing, Physiology, Environment and

Lung Disease”

* * * * *

As a working hypothesis, one may assume that the re-

peated microinsults to the lungs that occur each time a

worker is exposed to toxic dust, especially on Monday,

have a cumulative damaging effect. The damage mechan-

ism is not known. If the histamine release from mast cells

during acute exposure involves damage to cell walls, this

process might represent such a microinsult. Chronic lung

damage might result from these and possibly other micro-

insults on the cellular elements, if regularly repeated dur-

ing many years.

* * * * *

The practical significance of the functional grades (see

Table 17-3) is as follows:

F 0: no demonstrable acute effect of the dust on

ventilatory capacity; no evidence of chronic ven-

tilatory impairment.

F %: slight acute effect of dust on ventilatory ca-

pacity; no evidence of chronic ventilatory impair-

ment.

F 1: definite acute effect of dust on ventilatory ca-

pacity; no evidence of chronic ventilatory impair-

ment.

F 2: evidence of slight to moderate irreversible im-

pairment of ventilatory capacity.

F 3: evidence of moderate to severe irreversible im-

pairment of ventilatory capacity.

Increasing grades indicate increasing severity of func-

tional impairment. F % and F 1 indicate acute dust

26

effects. Workers in grade F 1 should, if at all possible,

be removed to jobs in nonrisk areas.

* = £ x +

Table 17-3

Recommended Functional Grades in Byssinosis

A FEV, + FEV,,,

Grade * (liters) (% of predicted )

FO —0.05-0; or + >80

F% — 0.06- —0.20 >80

Fl >- —0.20 >80

F2 — 60-79

F3 — <60

* If the grades based on (A FEV,,, and FEV,,, differ, assign the

highest of the two grades.

} Difference between FEV,,, before and after work shift on a

first working day of the week.

{ FEV,,, in the absence of dust exposure (2 days or longer) ; use

value postisoproterenol whenever this drug can be used.

27

EXHIBIT 6-44

Merchant, et al., “An Industrial Study of the Biological

Effects of Cotton Dust and Cigarette Smoke Exposure”

Until recently, little awareness had been expressed in

the U.S. medical literature about respiratory disease ac-

quired from working in the cotton textile industry.

* * * * *

It is the purpose of this paper to describe and quanti-

tate individual and combined effects of cotton dust and

cigarette exposure as associated with byssinosis preva-

lence and four parameters of ventilatory capacity. Be-

cause of the constraint of time, only white males em-

ployed in preparation and yarn processing areas will be

considered for statistical analyses.

Methods

Selection of the Population: Initially, a total of 22

North Carolina textile manufacturing plants were visited

to determine the grade and count of yarn manufactured,

plant layout, ventilation systems, machine exhaust sys-

tems and distribution of workers by sex, race, age and

work area. Twelve plants processed primarily cotton, five

cotton-synthetic blends and five either synthetic or wool

material. Based on information gained through these

visits and from a previous survey* which provided esti-

mates on the distribution of smoking habits, three strata

of exposure (cotton — high risk, cotton-synthetic blend

= moderate risk, synthetic-wool — low risk) were se-

lected for a three factor factorial design to fill adequately

four categories of age (15-29, 30-39, 40-49, 50-70), sex

and three categories of smoking habit (never smoked,

current smoker, former smoker). Initially two plants at

extremes of exposure were picked for the first two sur-

veys. From these surveys better estimates of demographic

characteristics and disease prevalence were sought to help

select other plants to fill categories of the factorial de

NE EF ee

28

sign. Other selection criteria were age of the plant,

whether it was associated with a mill village and prox-

imity to other mills under consideration. At least thirty

miles were allowed between plants.

Three cotton mills, all processing strict low middling

cottons, were selected. Mill A processed cotton with a

mean count of 6. Mill B with a mean count of 31, and

Mill C with a mean count of 33 plus 25% synthetic ma-

terial. Two cotton-synthetic blend mills processing pri-

marily strict middling cottons were selected. Mill D proc-

essed 50% synthetic material and 50% middling cotton

with a mean count of 29, and Mill E processed 49% syn-

thetic and both strict low middling and middling cottons

with a mean count of 32. The grade, count and mix of

materials had been relatively constant in the few years

preceding the study in all five cotton mills. Two synthetic

processing mills, Mill G and Mill H, processed only syn-

thetic material and one mill, Mill F, processed 100%

wool. All had previously been cotton mills but none had

processed cotton for more than 20 years. All mills selected

had once been associated with a mill village.

Within each mill up to four primary work areas were

defined. The preparation area included opening, blending,

picking, carding, drawing, combing and roving. The yarn

processing area included spinning, winding, twisting,

spooling and warping. Slashing and weaving operations

were combined to form a third primary work area. Other

employees studied were those employed in the warehouse,

shops, labs, supply areas, inspecting area, the yard and

administrative personnel. None of these employees could

be assigned a dust level since their dust exposure was

intermittent and variable.

29

EXHIBIT 6-51

Merchant, et al., “Dose Response Studies in Cotton

Textile Workers”

There is evidence of awareness of the fundamental as-

sociation between increased dust level and increased prev-

alence of respiratory disease among textile workers since

early in this century when efforts were made to minimize

disease through suppression of dust from the carding

engine.’ Although this concept of dose-response was ap-

preciated, it was not quantitated until 1960 when Roach

and Schilling * reported their study of the association be-

tween three fractions of cotton dust and its character-

istic biological response. They found the strongest linear

association between the protein content of the middle

- fraction of dust (7, to 2mm-Hexlet) but also a strong

linear correlation with total lint and dust. Because of this

strong association with gross dust concentration and the

simplicity and rapidity of sampling for total dust, they

recommended 1 mg/m* gross dust as a reasonably safe

level of occupational exposure. This recommendation was

adopted by the American Congress of Government In-

dustrial Hygienists and is the current threshold limit

value for cotton dust.®

Roach and Schilling recognized that some fine dust

(< 7) and medium dust (7u-2mm) was trapped on the

lint mat collected on the 2 mm screen, which. may have

reduced the correlation coefficients for these fractions.? 4

Subsequent observations showed that the fine fraction of

dust (< 7u) could account for nearly all of the prevalance

of byssinosis,® ** and that gross dust levels, particularly in

yarn processing areas (spinning, winding, twisting) could

be misleading indicators of biological effect. °° In recog-

nition of these findings, new standards for safe levels of

cotton dust exposure are being considered in Great Britain

and the United States.

The study described in this paper offered the opportun-

ity to observe biological effects in a large working popula-

30

tion over a wide range of dust exposure. The primary

objectives of this portion of the study were to evaluate

the vertical elutriator cotton dust sampler and to de

velop dose-response relationships to help establish the safe

level of exposure to lint-free cotton dust.

Methods

Definitions, the study design, and methods used in col-

lecting data are found in the Methods section of the pre-

ceding paper.“ As previously described, each worker was

assigned a mean, median and a geometric mean dust level

of his work area which was used to develop dose-response

curves. Although little difference was apparent in these

three measures of central tendency (Table 1), the median

Table 1.—Vertical Elutriator Dust Samples by Mill Type,

Work Area, Measures of Central Tendency and Range

North Carolina, 1970-71

Work Area

Mill Type Preparation Yarn Slash/Weave Total

Cotton

Dust Samples, n 260 131 102 493

Workers, n 215 494 367 1076

Mean .899 .303 .985 .654

Median .669 .257 .798 485

Geometric Mean .639 .201 .828 411

Range .090-3.56 .018-1.30 .227-2.74 .013-3.56

Blend

Dust Samples, n 130 61 46 237

Workers, n 164 398 146 708

Mean .264 .122 .682 .270

Median 163 .088 .683 .163

Geometric Mean 194 .097 .666 .169

Range .006-1.37 .006-.715 .292-.959 .006-1.37

Synthetic-Wool

Dust Samples, n 134 121 — 255

Workers, n 212 586 — 798

Mean .269 .157 — 191

Median .238 .186 — .186

Geometric Mean .232 114 — 138

Range 017-788 .013-.847 — 013-.847

31

dust level was chosen because it reduced the effect of out-

liers and provided the best distribution of the population.

Mathematical dose-response curves were fitted to data

on byssinosis prevalence by median dust level. Six groups

of workers (Table 2), including black and white men and

Table 2.—Six Worker Groups by Smoking Status

Byssinosis

Group Smoking Status Grades Exposure

z Current Smokers Grade 4, 1,2 Cotton/blend mill prep-

aration and yarn areas

= Never Smoked Grade 42, 1,2 Cotton/blend mill prep-

aration and yarn areas

3. All Workers Grade 42,1,2 Cotton/blend mill prep-

aration and yarn areas

4. All Workers Grade 144,1,2 Cotton/blend mill slash-

ing and weaving areas

5. All Workers Grade 2 Cotton/blend mill prep-

aration and yarn areas

6. All Workers Grade 1 and 2 Cotton/blend mill prep-

ar:.tion and yarn areas

women, in two primary exposure areas ( primarily cot-

ton dust and cotton dust plus sizing) by smoking status

are considered:

Raw data was categorized by arbitrary dust level

groups to provide a wide and balanced (as well as pos-

sible) distribution of workers by dust level (Tables 3, 4).

Because the number of workers above 1 mg/m? repre-

sented less than five percent of the total population and

was therefore likely to result in unstable rates, and be-

cause those exposed to these high dust levels were likely

to be a select, relatively more resistant group of workers,

they were eliminated from consideration for calculation of

linear regressions (except for Group 4). The truncated

regression plots and correlation coefficients are displayed

for this data in Figs 2, 3 and 4.

32

Table 3.—Demographic and Smoking Characteristics of Preparation and

Yarn Processing Workers in Cotton «>? Blend Mills by Median Dust Level

Dust 0 -057 0839 .1255 .1878 .2809 .4202 .6287 .9405 1.408

Level to to to to to to to to to to

-056 -0888 .1254 .1877 .2808 .4201 .6286 .9404 1.407 2.105

Men

n 70 34 104 144 61 122 69 65 80 42

Mean Age 39.5 36.9 38.7 42.1 33.6 87.8 $8.8 $7.1 41.4 38.7

% Current

Smokers 67.1 64.7 56.7 54.9 718.8 53.3 73.9 55.4 73.3 66.7

% Former

Smokers 14.3 23.5 19.2 22.2 9.8 18.0 10.1 16.9 18.3 14.3

% Black 5.8 8.8 7.7 19.0 26.2 29.2 27.5 36.9 13.3 64.3

Women

n 15 87 89 135 17 85 17 0 1 0

Mean Age 41.5 43.9 44.4 42.9 39.6 88.8 37.7 21.0

% Current

Smokers 44.0 $2.4 25.8 86.3 47.1 86.5 $2.5 0 0 0

% Former

Smokers 12.0 0 4.5 6.7 5.9 12.9 10.4 0 0 0

% Black 19.2 10.8 5.6 17.9 52.9 16.9 27.8 0 100.0 0

Percent change in FEV, with six hours of dust ex-

posure for cotton/blend mill preparation and yarn area

workers and synthetic/wool mill workers by dust level is

shown in Table 5. Linear regressions truncated at 1

mg/m were calculated and the regression lines and cor-

relation coefficients shown in Figure 6.

Kenneth A. Busch, National Institute for Occupational

Safety and Health, analyzed prevalence data using a pro-

bit model,’?** and developed Table 6 through 9 and the

probit curves in Figs 2 through 4. His protocol for an-

alysis was as follows: For each set of data, the method

of maximum likelihood was used to fit a straight line to

Y= probit (prevalence ratio) vs. X= log, (median dust

level in mg/m*). A chi-square goodness-of-fit test was

made to test jointly for both nonlinearity and excessive

variance about the fitted curve as compared to theoretical

results expected under the probit model. Ninety-five per-

cent statistical confidence limits were put upon the true

33

dose-response curve as well as upon predicted dust levels

corresponding to eight arbitrary levels of hypothetical

byssinosis prevalence: p= 1%, 2%, 3%, 4%, 5%, 10%,

25,% and 50%. Pairs of curves for Groups 1 and 2, and

for Groups 3 and 4, respectively, were tested for parallel-

ism and, if found to be parallel, a “relative toxicity”

metameter R was estimated along with its 95% confidence

limits. By “relative toxicity” is meant the ratio between

dust levels which produce the same prevalence of byssin-

osis in the two groups. Thus an R-value of 1.0 would

imply the two curves were coincident. When curves for

two groups are found to be non parallel, the difference be-

tween them is difficult to interpret since relative toxicity

would not be constant at all levels of response. In such

a case, a conditional relative dose metameter Rp was

calculated for several p-levels of prevalence of byssinosis

in the two groups.

Results

Table 2 summarizes 985 vertical elutriator (Fig 1)

dust samples by mill type, work area, measures of central

tendency and range. The greatest number of samples was

collected in the preparation areas of the cotton and blend

mills. The highest dust levels are recorded in the slash-

ing and weaving areas of cotton and blend mills where

sizing is used and contributes to the dust concentration,

Where sizing is not used, the dust levels in the prepara-

tion area were consistently much higher than in the

yarn processing areas. The mean dust levels were gen-

erally higher than the median or geometric mean levels,

reflecting the effect of high out-liers. In synthetic and

wool mills there was little difference in dust level between

preparation and yarn processing areas. The highest dust

levels in these mills were found in the preparation area

of the wool mill and the preparation area of a synthetic

mill where gasoline driven machinery was used.

34

Demographic and smoking characteristics for men and

women in cotton preparation and yarn areas by dust

level are shown in Table 3. No clear age trend is ap-

parent among men or women, nor is there a consistent

difference in the proportion of current or ex-smokers be-

tween dust subgroups. Among men, a greater precentage

of blacks were found with increasing concentration of

dust exposure. This was less apparent among women who

rareiy work in the dustiest areas of the mills.

Busch concluded from his analysis that the log-probit

model fitted the data well in every case. The points were

scattered randomly about the fitted dose-response curve

and the variance of deviations from the curve was not

significantly greater than would be expected based upon

an assumption of binomially-distributed prevalence ratios

at each dust level.

Slopes (b) and intercepts (a) of the fitted log-probit

dose-response curves, Y= a + bx, are shown in Table

6 together with three calculated points (ordinates Y) for

each fitted curve and their 95% confidence limits. The

curve equation was then inverted to predict dust levels

corresponding to arbitrary prevalence levels. Table 7

shows the predicted dust levels and their 95% confidence

limits for the six groups of workers for prevalence levels

of 1%, 2%, 3%, 4%, 5%, 10%, 25% and 50%.

Chi-square tests for goodness-of-fit of the individual

curves and for parallelism of pairs of curves (1 vs. 2

and 3 vs. 4) are shown in Table 8. Curves for current

smokers (Group 1) and those who never smoked (Group

2) were found to be significantly different although

nearly parallel but not coincident. A relative toxicity of

R= .56 with 95% confidence limits of R= .35 to R— .83

was found (Table 8) ; this suggests that only 56% (35%

to 83%) as much cotton dust is associated with any

given prevalence of byssinosis among smokers as among

¥

35

those who never smoked. Curves for all prepartion and

yarn workers (Group 3) and for all slashing and weav-

AIR FLOW

GONTROL SAGE

(LIMITING

ORIFICE)

Diigo: ©

VACUUM

—— PUMP

| SETTLING

— CHAMBER

VERTICAL ELUTRIATOR

COTTON DUST SAMPLER

~Fig 1.

FY

36

ing workers (Group 4) were not found to be parallel.

Therefore a single R-value was meaningless and it was

necessary to calculate R,-value as a function of eight

arbitrary prevalence levels which are shown in Table 8.

Curves for Groups 3 and 4 were found to be significantly

different but yielding R,-values which ranged from .087

at a byssinosis prevalence of 1% to .56 at a prevalence

of 50%. Therefore, only approximately 9% (4% to

15%) as much cotton dust is associated with a 1% bys-

sinosis prevalence for workers in the preparation and

yarn areas of cotton mills as compared to the amount re-

quired for the same prevalence for cotton slashing and

weaving workers. At a prevalence of 5% an average of

15% as much dust is required, as a prevalence of 25%,

32% as much, and at the 50% prevalence level 56% as

much dust is required.

The probit-dose response curves are shown in Figs 2,

3, 4, together with the linear regression plots and cor-

relation coefficients. The truncated linear plots are ob-

served to fall within the 95% confidence limits of the

probit curves below a dust level of 0.5 mg/m*. Both dose

response curves for cotton slashing and weaving workers

fell nearly on the same line through 2.0 mg/m? of dust.

The strength of the linear association between dust level

and byssinosis prevalence was uniformly high except for

those who had never smoked (Group 2) where the cor-

relation coefficient was .52; however, one subgroup within

this population contained only seven workers, none of

whom had symptoms of byssinosis. Expected byssinosis

prevalence levels are shown in Table 6 and the curves

plotted for Groups 3, 5 and 6 in Figure 4. Prevalence of

Grade 2 byssinosis (Group 5) ranges from 1.3% (0.7-

2.3) at 0.1 mg/m* to 3.0% (2.1-4.3) at 0.2 mg/m to 8.0

\6.1-10.2) at 0.5 mg/m*, as computed from the probit

curve. When Grade 1 and 2 byssinotics are combined

(Group 6) the probit prevalence levels are 2.1% (1.3-

3.3) at 0.1 mg/m’, 5.0% (3.9-6.6) at 0.2 mg/m? and

13% (10.7-15.8) at 0.5 mg/m‘,

72

37

Table 5 and Fig 5 show percent change in FEV,, with

increasing levels of exposure among cotton preparation

and yarn area workers and synthetic and wool workers.

The truncated linear regression (Fig 5) for the cotton

population again showed a strong linear association (r —

.82) between biological effect and dust level. No decre-

ment in percent changes in FEV,, is seen with increasing

levels of exposure to synthetic and wool dust.

Discussion

Dust Sampling.—In the year preceding this study, sev-

eral cotton dust sampling techniques were evaluated."

The sampling device desired was to be relatively easy to

operate, portable, durable, operable unattended for a full

shift and provide a lint free dust sample. Of the sam-

pling devices evaluated, the vertical elutriator developed

by Lynch and Lumsden * was found to best fulfill these

criteria. The instrument was designed to sample dust

with a mass median aerodynamic diameter of 15. and

less which effectively eliminated biologically inert lint

while retaining particles of the size expected to be in-

haled. Since high correlations between byssinosis symp-

toms and dust level have been observed with the middle

fraction (7. to 2mm) of dust, *" it was thought that

larger particles (7y-15,) as well as “respirable” parti-

cles (<7) should be collected. An added practical ad-

vantage of including larger particles is the accumulation

of a weighable sample in a shorter interval. A potential

disadvantage was the possibility of including fine but

inert “linters” in the sample. This has been observed

rarely in our experience and appears to occur only under

the dustiest of conditions when exact dust levels are not

as important.

In the absence of a specific assay for the etiological

agent(s) responsible for the biological effects of cotton

dust, the most important consideration in evaluating a

38

Table 4.—New Data on Byssinosis Prevalence vs.

Median Dust Levels for Six Groups of Workers

Mid-Point * of Range Sample Cases of

of Median Dust Levels Size Byssinosis Prevalence (%)

(mg/m) n r p = r/nx 100

Group 1. Cotton Preparation and Yarn Areas

All Grades—Current Smokers

.05 167 10 6.0

15 159 21 13.2

25 82 14 17.1

35 64 14 21.9

45 55 15 27.3

55 26 11 42.3

75 31 16 51.6

1.1 12 5 41.7

1.5 12 7 58.3

1.9 26 12 46.2

Group 2. Cotton Preparation and Yarn Areas

All Grades—NonSmokers

15 127 3 2.4

15 145 9 6.2

.25 44 2 4.5

35 ? an 16 29.6

45 49 12 24.5

55 7 0 0

75 18 5 27.8

1.1 2 0 0

1.5 8 2 66.7

1.9 8 3 37.5

Group 8. Cotton Preparation and Yarn Areas

All Grades—All Workers

.0458 145 5 3.4

.0686 71 2 2.8

.1026 193 14 7.3

.1535 279 27 9.7

.2296 78 10 12.8

3435 208 89 18.8

.5139 147 87 25.2

-7689 65 80 46.2

1.150 81 14 45.2

1.722 42 17 40.5

* Arithmetic mean of end-points used for groups 1, 2, 4.

Geometric mean of end points used for groups 3, 5, 6.

39

Table 4.—Continued

Mid-Point * of Range Sample Cases of

of Median Dust Levels Size Byssinosis Prevalence (%)

(mg/m?) n r p = r/nx 100

Group 4. Cotton Slashing and Weaving Workers

All Grades—All Workers

35 15 1 6.7

45 136 7 5.1

55 2 0 0

75 195 14 7.2

1.1 34 6 17.6

1.5 87 23 26.4

1.9 44 16 36.4

Group 5. Cotton Preparation and Yarn Areas

Grade 2

.0458 145 0 0

.0686 71 1 1.4

.1026 193 2 1.0

.1535 279 9 3.2

.2296 78 1 1.3

3435 208 8 3.8

.5189 147 14 9.5

-7689 65 11 16.9

1.150 81 6 19.4

1.722 42 6 14.3

Group 6. Cotton Preparation and Yarn Areas

Grades 1 & 2

.0458 145 0 0

.0586 71 2 2.8

.1026 193 2 1.0

.1535 279 11 3.9

.2296 78 2 2.6

3435 208 23 11.1

.5189 147 22 15.0

.7689 65 15 23.1

1.150 31 8 25.8

1.722 42 9 21.4

* Arithmetic mean of end-points used for groups 1, 2, 4.

Geometric mean of end points used for groups 8, 5, 6.

40

OVSSImS 1S PwL VaR CECE OF MOLAR GUST LK WiR fora COTTOm FFF ita

AAD TAGK An(A mUPEL PS B00 COTTCM WASHi at dau sf beim, My :

LIRGAR MLGALSSICHS O00 FITETO PLSiT (org -PELPMELE CRY —<

70r AAO [MEiR GSE COMPILE LIMITS.

moate Cary ima, 19/0-7!

-

eer

ws | wa GROUP 3

$ ae (r*.99)

7° po =

a Ya ora

- or a

= 50 - me m

< ° Pr as we

< a ” nn“ oa?

= a a oo”

« SOF ZA

= ,

s a

4 7

= 30 a

= y/ A Pa

a 4 a ogi

sO

e 4 7

ne 4 of

¢

° 20- 4 4

c i

a 14 ‘7

*

a 1p Group 3 (0) CPY |

Group 4 (a) CSW

*

f

£ “

a. waa - ; oe s

On' 2.345 l 5 —

Medion Dust Level (mg/m*)

Fig-2

gravimetric sampling technique is the degree of correla-

tion with biological indicators over the range of exposure.

As shown in Figs 2 through 5, a strong linear associa-

tion was found in this population, particularly below 0.5

mg/m‘*, the level below which the majority of the popula-

tion is exposed and where attention is focused concerning

establishment of a reasonably safe exposure level.

As a field instrument the vertical elutriator cotton

dust samplers have proven to be most practical and dur-

able. The 25 samplers built for this survey have now been

in use for two years and have collected over 3000 sam-

ples. No modification of the instrument or the sampling

procedure has been necessary. Its design lends itself to

use within the manufacturing plant; at no time has it

ie

OTSSIMOSIS POEVAL ENCE BY PCOL AM OUST CIVIL AMONG CyeetaT coOctes

FAD THISE oO SETCR SHOKTD, COTIOM PREPARATION AMO YAPH AREA WORKERS:

RiALAR AIGAESSIONS AMO FITTCD POOSTT TOSE-aLSPONSE CURVES.

WORTM CAROLIAA, 1970-71

7Or

60

°o _

=

-

a

ae om ow

50- GROUP | po na pail

(ce.98) an Same,

-

= an °

o* -”

a rd

- ° -*

40 a

ail “4

GROUP 2

30 dr .52)

20

Group | (©) Smokers

Group 2(4) Non-smokers

Cyssinosis Prevalence (%)-All Grades

=

ee, Pee ak eS i =" 1 i fe

staat & 1 ie) 2

Medion Dust Level! (mg/m)

Fle 2X

interfered with the manufacturing process or personnel.

Sampling with this instrument can easily be learned and

could be used by manufacturing personnel to monitor

their working environment.

Dose-Response.—In developing dose-response curves for

byssinosis, tables were developed by sex, smoking groups,

work areas (preparation, yarn production and slashing/

weaving) and mill type (cotton and blend). A strong

linear association was repeatedly observed in these sub-

populations. Since there appeared to be no difference in

age between individual dust level subgroups (Table 3),

there was no reason to age adjust the data. Similarly,

no difference in byssinosis prevalence has been found in

men and women, allowing both to be considered together.

42

Preparation and yarn processing areas are justifiably

combined since the dust is of the same composition, the

dose-response curves for each area are similar, and the

areas are frequently continguous. When the yarn arrives

in the slashing department, sizing is added to the yarn

and has been found consistently to increase the concen-

tration of lint free dust in the slashing and weaving

areas. Therefore, the biologically active airborne material

in these workrooms is diluted with biologically inert. siz-

ing, making it necessary to consider this dust separately

when considering these significantly different dose-re-

sponse relationships. Cigarette smoking has been found

to significantly increase byssinosis prevalence * 1! 1°17 and

must therefore be considered a potential source for a sec-

ondary association. Table 8, however, shows no apparent

difference in smoking habits between dust level sub-

populations. Probit analysis revealed that byssinosis

prevalence for smokers was significantly higher than for

non-smokers. Although it may be argued that the most

Susceptible group (smokers) should be most closely con-

sidered when recommending safe levels of exposure, the

majority of this working population smoke cigarettes and

the dose-response curves for current smokers and all

workers regardless of smoking habit are similar. For this

reason, and because a standard generally applies to the

entire population at risk, consideration of the entire pop-

ulation regardless of smoking habit appears to be most

appropriate.

As initially observed by Roach and Schilling,” and later

confirmed by El-Batawi,'® Molyneaux,”® and our group in

an independent study,”® dose-response curves for the asso-

ciation between dust level and byssinosis prevalence and/

or change in FEV,, are strikingly linear. This was found

repeatedly in this data no matter how the groups were

divided, unless the number of workers in the dust level

sub-populations was so low as to produce unstable rates

43

(Group 2, r = .52, Fig 3). With this exception, correla-

tion coefficients were consistently above 0.9. Similarly,

the association between percent change in FEV,, and

median dust levels was also strong (r = .82, Fig 5). A

source of increase variance in this measurement is di-

urnal variation in expiratory flow rate which was ob-

served but not adjusted out. The distribution of workers

by shift within dust level sub-populations was similar and

therefore unlikely to produce a secondary association.

Above a median dust level of 1 mg/m® the dose-response

curves tend to flatten. We suspect that selection, leaving

relatively resistant workers in these dustier areas, is re-

sponsible for this decrease in prevalence and percent

change in FEV,.,. As reviewed in the preceding article,

there is substantial evidence of selection away from dust

exposure in this industry.®**! In Table 3, a consistent

trend toward a higher percentage of black men was found

with increasing dust level. Blacks have been found to

have lower rates of chronic bronchitis than whites of

Of Crore 61 iL Iee Ort

wOteded Gnd Semied i itsmde woeeert.

‘

7

aon, tony ~ bes — ond °

‘orn Workers (0)

4 Fad £2.82

*%O,FEVIO

: ;

4

n

+2

L

1 i _, i i — i

Oo 04 02 03 04 05 06 0.9 | 1.3

MEDIAN OUST LEVEL (mq/m?)

Fig 4

44

Table 5.—Raw Data on Percent Change in FEV,,, vs. Median Dust

Level among Preparation and Yarn Area Workers in Cotton/ Blend

Mills and Workers in Synthetic/Wool Mills

Cotton/Blend Synthetic/Wool

Mid-Point of Range of Mills Mills

Median Dust Levels n mean §.D. n mean S.D.

(mg/m?) % AFEV,,, % AFEV,.,

0.05 299 0.4 9.4 241 0.7 5.5

0.15 309 0.5 9.8 212 0.2 7.0

0.25 118 —1.8 10.0 141 6.7

0.35 130 —4.2 6.1 112 0.7 7.0

0.45 95 —2.6 16.2 7 0.2 3.3

0.55 85 —2.0 8.8

0.75 61 —4.9 10.1

1.10 146 —0.9 10.3

1.50 © 12 —2.7 6.0

1.90 385 —5.6 10.9

Table 6.—Parameters of Log 10-Probit Dose-Response Curves and Three Points

on Each Fitted Curve with Their 95% Confidence Limits

Intercept Slope Expected Prevalence (%)

Group (a) (b) -1 mg/m*® .2 mg/m? -56 mg/m?

4.826 1.108 10.0% (7.3-13.38) 17.1% (14.2-20.5) 30.6 % (25.9-85.6)

1

2 4.641 1.301 4.9% (2.8-7.9) 10.2% (7.5-13.6) 22.7 % (17.0-29.8)

3 4.718 1.226 6.5% (5.0-8.5) 12.7% (10.8-14.9) 25.8 % (22.5-29.3)

4 3.966 2.134 0.08% (0.01-0.7) 0.6% (0.1-2.1) 4.7% (2.7-7.7)

5 3.944 1.170 1.8% (0.7-2.3) 3.0% (2.1-4.3) 8.0% (6.1-10.2)

6 4.269 1.304 2.1% (1.3-8.3) 5.0% (3.8-6.6) 13.0 % (10.7-15.8)

the same age and environmental exposure.”? The rela-

tively greater number of blacks with relatively lower

response at high dust levels in this textile population

may represent another example of ethnic difference in

susceptibility to the biological manifestations of inhal-

ants. Further analyses of this data are being done to

determine whether this is a sociological or a biological

problem.

Another important observation concerning these dose-

response curves is that there appears to be no threshold

beneath which no one with Monday chest tightness was

found (Table 4). This indication that low dust concentra-

tions result in measurable effects suggests that cotton

45

(¥°L-8°Z) 9°8 (9°82-6°8) 0° (¥°9°3°S) T'S (L°O-3'T) Lt (S°S-T'T) 6'T (9°S-L6") OT %03

(9°T-P8") T°T (9°F-P'T) 1S (6T-S'T) 9°T (69°-0") 8h" (L6°-Th*) LS" (L¥°-82") 98° %3

(9F°-18") 88° (86°-6)") b9° (06°-29") LL" (8T°-Z1") ST" (93°-b1") 02° (¥T°-990") OT" ot

($Z°-S1") 02° (1h"-b2") 18° (¥9°-98") 29° (OT*-¥90") LL0° (ST"-L90") OT° (1L0°-8Z0") LbO° %s

(12"-Z1") 91° (88°-81") 92° (89°-18") 9P° (¥80°-8F0") 890° (Z1°-#F0") 980° (690°-610") 880° %y

(LT°-160") 81° (92°81) 02° (Z9°-92") OF" (890°-Z80") 090° (0T"-180") 890° (L¥0°-810") 620° yd}

(81°-890") L60° (61°-980") PT" (Sh°-61") 88° (19°0-1Z0") 980° (180°-020") 090° ($80°-800") 020° 2%

(980°-F80") 090° (Z1°-2b0") 280° (98°-Z1") 93° ($80°-Z10") 120° (990°-010") 180° (2Z0°-600") L10° Mt

9 dno g dnoin p dnoin ¢ dnoiy Z dnoary I dnowy aouspeaaig

(gui/Bul) jaa] ysnq pezorperg

SSOUJSEA JO BoUBTBArIG JO SOAs] AIBIZIGQIY 103 syUII'] EOUePYUOD %96 IIEYL, pus spear] yong p2}o1perg—"), a1qBI,

46

dust is a highly biologically active inhalant. British stud-

ies reported by Molyneaux and Berry™ also found no

threshold for the biological effects (byssinosis and simple

bronchitis) of respirable dust (<7,-Hexlet) and middle

fraction dust (7. to 2mm-Hexlet). Although these dust

fractions and the vertical elutriator dust fraction are not

strictly comparable, they do contain much of the same

dust distribution. When their dose-response regressions

are plotted with those presented in this paper, there is

good general agreement both in origin and slope. At 0.2

mg/m*, both sets of curves reveal roughly 15% with some

grade of byssinosis. As has been observed before, surpris-

ing uniformity in byssinosis prevalence has been found

in cross-sectional surveys despite differing populations,

working conditions, and frequently somewhat different.

methods of study.

OTISIMOSIS POL VALE RCE BY COSTE Am) OF ole -- A... Ate

70r AMO8S COTTIOS PRL PSRAT ICN On9 TAPe Byta

RPMEAR ALCALSS 10nd Ory FITTEG beretl COM. me pOrse Connts.

sOuin Cama ina, 1970-7)

om

o

T

-_s

--"

on

--

w

Oo

oo

a

af GROUP 3+ 2 Gredey (0)

(e*39)

a

2]

°

PP a

ow”

-" GROUP 6- Gredes 182 (a)

(r*.98)

ul

o

---"

--—~ nour s- - Ge

-_ ede 2 (5)

(r*.$6)

Byssinosls Prevalence (%)

tv

oO

)

1

—

Median Dust Level (mg/m3)

Fig 5.

47

Table 8.—Chi-Square Tests for Goodness-of-Fit of the Log-Probit

Model and for Parallelism of Pairs of Fitted Lines.

Goodness-of-Fit Parallelism

Group x? df P x? df P

1 6.0 8 .65

2 14.1 8 .08

3 7.5 8 52

4 3.8 5 .58

5 8.3 8 .60

6 10.0 8 .26

1&2 20.1 16 21 0.53 1 AT

3&4 11.3 13 .59 6.0* 1 .015

Symbols: df=degrees of freedom

P=probability of x? as large or larger than observed

value

* = significant at the .05 probability level

Table 9.—Relative Toxicities and Their 95% Confidence Limits

Byssinosis Prevalence Relative Toxicity

Groups P R 95% Confidence Limits

1&2 All levels 56 .35 to .83

3 & 4+ 01 .09 .04 to .17

02 ll .06 to .19

.03 12 08 to .20

.04 14 .09 to .21

.05 15 -10 to .22

10 .20 -15 to .26

25 32 .24 to .43

.50 56 32 to .96

Symbols: P=No. of subjects with byssinosis/total No. of subjects

R=ratio of dust levels producing same prevalence (eg.,

dust level for group 1/dust level for group 2)

+=Note: Dose response curves for groups 3 and 4 are

non-parallel, so that relative toxicity varies

with level of prevalence

48

The log-probit model was found to fit this data well

and offers the opportunity to consider prevalence at fixed

dust levels and conversely, calculate dust levels from any

given level of prevalence. This is clearly very useful when

considering data for setting standards. Probit analysis

(Table 6) shows the expected byssinosis prevalence for

all grades of byssinotics at 0.2 mg/m* to be 12.7%, while

only 3.0% for Grade 2 byssinotics. In order to determine

what a reasonably safe level of lint free dust might be,

the question is raised whether all grades of byssinosis or

only Grade 2 byssinosis prevalence is the appropriate

indicator. We concluded that overall byssinosis prevalence

best estimated byssinosis risk since it was likely to be

less affected by selection than Grade 2 byssinosis. In our

experience, workers usually do not consider selecting

themselves out of exposure if they have only occasional

chest tightness or tightness which is not severe and con-

fined to Monday. Those with tightness on Monday and

other days (Grade 2) frequently also complain of dyspnea

and fatigue; as a result it is not uncommon to find that

these workers request a change in job location. There-

fore, those with Grade 2 byssinosis symptoms are likely to

represent a highly selected group which would very likely

result in an underestimation of risk.

Also to be considered is the sensitivity of the biological

indicators used in this study; the standard indicators in

studying the effects of cotton dust have been byssinosis

symptoms and change in FEV,.,. There is now evidence

that use of flow-volume loops ***** and measurement of

the leukocyte response * increase sensitivity in detecting

biological effects. Therefore, because of selection and be-

cause the indicators of response in developing this dose-

response data although well standardized are probably

still dull tools, we conclude that, for cotton and blend mill

preparation and yarn areas, a reasonably safe level of

cotton dust exposure is 0.1 mg/m*. Even at this low level

an expected byssinosis prevalence of 6.5% was found by

49

probit analysis. A separate level of 0.75 mg/m is sug-

gested as a reasonably safe level in slashing and weaving

areas. It will be necessary to include in any cotton dust

standard provisions for periodic testing of workers to

detect those most susceptible and to avoid placement of

those with impaired lung function in dusty areas.

Dust Control.—There is now substantial evidence that

biological effects result from low levels of lint-free cotton

dust exposure, even with relatively crude indicators of

response. To make the cotton textile mill working envi-

ronment reasonably safe, very great strides must be

taken in controlling fine dust. Initially, this requires a

reorientation in thinking regarding dust handling from

suppressing primarily lint to suppression of fine dust as

well. Currently, machine exhaust and ventilation and

filtration systems are designed primarily to control lint

and large dust particles and not fine dust. As a result,

the workroom frequently appears lint free and relatively

clean, yet lint free dust levels may be relatively high. To

solve this problem, two basic approaches may be taken.

One is the traditional approach of dust control after the

dust has been introduced into the mill; the second is re-

moval of dust from lint prior to manufacturing. Clearly,

the most desirable approach would be a method to harvest

cotton without contamination with trash. New methods

to improve picking are now under consideration. Dust

reduction at the ginning stage would be the next most

desirable location to control dust. There is now experi-

mental evidence that the application of steam to cotton is

compatible with manufacturing and reduces lint free

dust levels and biological activity by roughly one half.’

A plant wide intervention trial is now underway to test

the effectiveness of steaming under manufacturing condi-

tions. The feasibility of steaming cotton at a gin is also

being tested. Although steaming may provide improve-

ment in environmental conditions, it is apparent that

50

much improved dust control, particularly in preparation

areas will also be required.

Table 2 shows that lint free dust levels are particularly

high in the preparation areas of cotton mills. Review of

dust levels from six cotton mills (three from this study;

670 samples) revealed vertical elutriator median dust

levels of 1.50-1.59 mg/m* in opening and blending areas,

1.60-1.69 mg/m* in picking areas, 1.70-1.79mg/m* in

carding areas, then dropping to 0.70-0.79 mg/m* in

drawing, 0.40-0.49 mg/m* in roving, 0.20-0.29 mg/m? in

spinning, winding and twisting, and then up again in

weaving to 1.00-1.09 mg/m*. In eleven blend mills (50%

cotton or less), two of which are part of the study re-

ported in this paper, 1232 vertical elutriator dust samples

found a median dust level of 0.30-0.39 mg/m* in opening

and blending, 0.50-0.59 mg/m* in picking, 0.60-0.69

mg/m in carding, 0.30-0.39 mg/m* in drawing, 0.10-0.19

mg/m? in roving, 0.00-0.09 mg/m? in spinning. 0.10-0.19

mg/m’ in winding and twisting and 0.50-0.59 mg/m* in

weaving areas.”° In these eleven blend mills, the spinning

and weaving areas show median dust levels that may be

considered reasonably safe and levels in roving, winding

and twisting approach this level. Since less than 10% of

the work force is employed in areas preceding roving,

roughly 90% of those working in these eleven blend mills

could be considered as working in a reasonably safe or

marginally safe working environment. Those remaining,

although exposed to hazardous dust levels, are working in

a third or less the dust concentration of their counter-

parts in cotton mills.

By contrast, it appears from these figures that there is

no work area in the cotton mills that could be considered

reasonably or marginally safe, although yarn processing

and weaving areas are not far from these levels. The

areas clearly in acute need of attention are those of

opening, blending, picking and carding. Because drawing

51

and roving are almost invariably in the same work area

as the carding engine, much of the dust exposure in these

latter two areas probably arises from the carding engine.

To protect these workers, the carding area should be

partitioned from drawing and roving and each area pro-

vided with an independent ventilation system. Under

such conditions the dust levels in drawing and roving are

expected to more closely approximate those in spinning.

Close attention to recirculation of lint free dust (< .05

mg/m*)* should further reduce dust levels to more ac-

ceptable levels. Preprocessing removal of fine dust by

steam may also contribute to achieving safe levels in

these areas. But even if steaming were to reduce dust

levels by a half, the processes of opening, blending, pick-

‘ng and carding will require efficient exhaust systems.

“‘ortunately, in each of these machines, the area in which

the fiber is most vigorously processed is in a relatively

enclosed part of the machine. Further enclosure of each

of these machines with well designed exhaust systems

does not appear to be insurmountable. Efficient removal

of fine dust, without recirculation, should markedly im-

prove these preparation areas and perhaps could also

remove some dust which previously was released from

the yarn in subsequent processes, thereby contributing to

control in these work areas.

In summary, the following statements can be made:

1. This study confirms the finding of others, that a

strong linear association exists between prevalence of

byssinosis and decrement in expiratory flow rate with

concentration of lint free dust.

2. The log-probit model, curves of which followed the

linear regression plot below 0.5 mg/m*, fit this data well

and provided both expected byssinosis prevalence and

conversely expected dust levels, both of which proved to

be useful in interpretation of the dose-response relation-

ship.

52

8. Based on these curves, it is concluded that a reason-

ably safe level of lint free cotton dust is 0.1 mg/m’, a

level at which nearly 94% of the population exposed were

found to have no symptoms of byssinosis. A separate level

of 0.75 mg/m is suggested for slashing and weaving

areas.

4. Probit dose-response curves for smokers and those

who never smoked, showed that smokers had a signfi-

cantly higher prevalence of byssinosis.

5. The vertical elutriator cotton dust sampler, over a

period of two years, has proven to be a durable and prac-

tical instrument which collects a biologically active lint

free fraction of dust linearly associated with indicators

of biological response.

6. Lint free dust levels by work area suggest that no

work areas in the cotton mills sampled had reasonably

safe dust levels and that the areas of opening through

carding had very high levels. By contrast, in blend mills

all areas beyond drawing had reasonable safe or margin-

ally safe dust levels while levels preceding roving are

considered only moderately elevated.

7. It is recommended that carding machines be isolated

from drawing and roving processes by partitioning and

the use of independent ventilation systems.

8. Serious attention should be given to more complete

enclosure of opening, blending, picking and carding ma-

chines and design of a highly efficient exhaust system to

remove fine dust.

9. At the present time, a successful occupational health

program for the cotton textile industry should include

efforts to remove or reduce dust prior to processing, effi-

cient machine exhaust and ventilation systems, and med-

ical surveillance to detect susceptible workers before they

acquire permanent pulmonary impairment.

53

The authors express their appreciation for the guid-

ance of Drs. Ben Drake and Martin Hines, the advice of

Drs. Carl Shy and Al Tyroler, data processing provided

by Joe Rouchard and Jim Holmes, the advice and contri-

bution of Howard Ayre, J erry Lynch and Kenneth Busch

in analysis of data, and for the cooperation and partici-

pation of the employees and management of Burlington

Industries.

References

1. Collis EL: Industrial pneumoconioses with special

reference to dust phthisis (Milroy Lectures, 1915), Pub-

lic Health 28:252-253, 1915; 29:11-20, 37, 44, 1916.

2. Roach SA and Schilling RSF: A clinical and envi-

ronmental study of byssinosis in the Lancashire cotton

industry, Brit J Industr Med 17 71-19, 1960.

3. Committee on Threshold Limit Values for Airborne

Contaminants, Threshold Limit Values for 1971, Ameri-

can Conference of Governmental Industrial Hygienists,

Cincinnati, Ohio, 1971.

4. Schilling RSF: The history of byssinosis and the

British experience. Transactions of the National Con-

ference on Cotton Dust and Health, pp. 7-12, 19-20, Uni-

versity of North Carolina, Chapel Hill, North Carolina,

1970.

5. McKerrow CB, et al: The size of cotton dust par-

ticles causing byssinosis: An environmental and physio-

logical study, Brit J Industr Med 19:1-8, 1961.

6. Wood CH, Roach SA: Dust in cardrooms: A con-

tinuing problem in the cotton-spinning industry, Brit J

Industr Med 21:180-186, 1964.

7. Molyneaux MKB, Tombleson JBL: An epidemio-

logical study of respiratory symptoms in Lancashire mills,

1963-1966. Brit J Industr Med 27 :225-234, 1970.

54

8. Hammad YY, Corn M: Hygienic assessment of air-

borne cotton dust in a textile manufacturing facility,

Amer Industr Hyg Assoc J 32:662-667, 1971.

9. Merchant JA, et al: Byssinosis and chronic bron-

chitis among cotton textile workers, Ann Int Med 76:423-

433, 1972.

10. Lumsden JC, et al: Cotton dust sampling. In

preparation.

11. Merchant JA, et al: An industrial study of the

biological effects of cotton dust and cigarette smoke ex-

posure. Proceedings of the 1972 Skytop Conference on

Respiratory Disease in Industry, J Occ Med 15:1973.

12. Busch KA: Probit analyses of data on prevalence

of byssinosis in working populations exposed to cotton

dust. National Institute for Occupational Safety and

Health Memo. February, 1972.

13. Finney DJ: Probit Analysis, A Statistical Treat-

ment of the Sigmoid Response Curve, Cambridge Uni-

versity Press, 1962.

14. Lynch JR: Air sampling for cotton dust. Transac-

tions of the National Conferences on Cotton Dust and

Health, pp. 33-48. University of North Carolina, Chapel

Hill, North Carolina. 1970.

15. Molyneaux MBK, Berry G: The correlation of

cotton dust exposure with the prevalence of respiratory

symptoms. Proceedings of the International conference on

Respiratory Diseases in Textile Workers. pp. 177-183.

Alicante, Spain, 1968.

16. Schilling RSF: Epidemiological studies of chronic

respiratory disease among cotton operatives, Yale J Biol

Med 37 :55-74, 1964.

17. Carey GCR et al: Byssinosis in flax workers in

Northern Ireland. HMSO, Belfast, 1965.

55

18. Batawi MA El, et al: Byssinosis in the Egyptian

cotton industry: changes in ventilatory capacity during

the day, Brit J Industr Med 21:18-19, 1964.

19. Merchant JA, et al: Preprocessing cotton to pre-

vent byssinosis. In press, Brit J Industr Med.

20. Gandevia B, Milne J: Ventilatory capacity changes

on exposure to cotton dust and their relevance to byssi-

nosis in Australia, Brit J Ind Med 22 :295-304, 1965.

21. Elwood PC: Respiratory symptoms in men who had

previously worked in a flax mill in Northern Ireland, Brit

J Industr Med 22 :38-42, 1965.

22. Densen PM et al: A survey of respiratory disease

among New York City postal and transit workers,

Environ Res 1:265-286, 1967.

23. Bouhuys A, et al: Maximum expiratory flow rates

in induced bronchoconstriction in man, J Clin Inv 48:

1159-1168, 1969.

24. Merchant JA, et al: Assessment of clinical indi-

cators of response to cotton dust. International Confer-

ence on Biological Responses to Organic Agents. Trans-

actions of the New York Academy of Sciences, in press,

1972.

25. The Advisory Committee to the National Confer-

ence on Cotton Dust and Health. The Status of Byssi-

nosis in the United States, Arch Environ HIth 23 :230-

234, 1971.

Supported in part by a grant from National Institute

of Environmental Health Sciences. Grant No. 2TO1ES-

00124 and by a grant from the National Institute of

Occupational Safety and Health, Grant No. SRO1

0H00302.

BYSSINOSIS PREVALENCE (per cent)

56

EXHIBIT 6-55

Molyneux & Berry, “The Correlation of Cotton Dust

CN

Oo

t

40.

nO

o

o

Exposure With the Prevalence

of Respiratory Symptoms”

* * * « *

FIGURE 4

CORRELATION. BYSSINOSIS IN FIVE OCCUPATIONS

945 Subjects

z= 0.766 (excluding ringspinners)

i + Po wingspinners

ay

, 4

0.2 0.4 0.6 0.8 1.0

MEDIUM DUST (mg/M*)

DYSSINOSIS PREVALENCE (oer cent)

SIMPLE BRONCHITIS PREVALENCE (per cent)

57

FIGURE 5

CORRELATION. CYSS:INOLIS IN SPELNFRAIME TENTERS

60.

40.

20 -

0,2 0.4 0.6 0.8 1.0

MEDIUM DUST (m9/ta*)

FIGURE 6

CORRELATICN SUPLE DRONCHITIS in non sras! cers (35-54 years)

60 + 17i Suijects

x= 0.619 he

40 -

20 ||

CH ringsdinners

0

: q AY ‘ Ce ? oe

0, 2 0.4 0. 6 0.5 4 .

RESPIRACLE OUST (ms/At’)

58

EXHIBIT 6-57

Experience with Medical Surveillance Programs

By: Harold R. Imbus, M. D., Sc.D.

Medical Director

Burlington Industries, Inc.

* * * * *

Nevertheless, one can see the marked difference in the in-

cidence of symptoms of tightness in the chest and in the

decline of FEV, in these employees. Only one employee

has Grade I byssinosis. This is now becoming a man-

ageable situation in which medical surveillance can iden-

tify susceptible individuals, monitor their respiratory

function periodically, advise regarding respirators, and

smoking habits, and even consider transfer if necessary.

Table II illustrates the card room of another plant. In

early 1971 an initial survey was done. Dust levels were

high. and Column 1 shows clearly that there is a sig-

nificant problem and something needed to be done.

Clearly there was little more that a medical surveillance

program could do than to identify the problem, which was

too much dust. Control measures were instituted shortly

thereafter with installation of new card cleaning equip-

ment. You can see from Column 2 that dust levels were

lowered by about two-thirds and so was the percentage

with symptoms of byssinosis. Decrement in FEV, was

also decreased significantly. However, further improve-

ment here is highly desirable. Unfortunately, many tex-

59

tile plants find themselves in this position, having in-

stalled ventilation equipment, in the last few years, at

large expense, which though what was generally available,

is not adequate to control the byssinosis problem. At this

time, an entirely new installation of chute feed carding

is in process in this plant’ and dust levels will be much

lower in the near future. Likewise, it is anticipated that

the number of reactor employees will be much lower.

Table III, left side, illustrates a survey of a card room

and drawing area in a rather large cotton blend plant

which has spun cotton yarn for many years. Dust levels

in bot areas are approximately .4 milligram per cubic

meter. In the card room, no employee has symptoms of

byssinosis and only one (3%) had a decrement of 10%

or more in FEV,. It is seen that average FEV, actually

increases during the working day. In the drawing area,

3.2% have byssinotic symptoms and 6.5% have a decre-

ment of FEV, of 10%, an average decrement of 48ce,

about what we have at our Corporate Headquarters.

This plant uses a higher grade of cotton blend and it ap-

pears that we have an entirely manageable situation.

With medical surveillance, any employee having problems

can be detected early and protected either with a respira-

tor or by transfer.

On the other hand, Table III, right side, shows a small

area in another plant with dust levels somewhat com-

parable, but incidence of symptoms and decrement of

FEV, is much greater. Other areas in this plant were

found to have even higher dust levels, but I show these

areas because dust levels are in the same “ball park.”

This is a 100% cotton plant. Even though dust levels

here do not look inordinarily high, it is obvious that

further action needs to be taken to lower them, and

medical surveillance is strictly an interim measure.

* * * * od

60

The point I am trying to make by using these examples

is that in order for a medical surveillance program to

provide any real protection you must first of all have a

manageable situation.

* * * + e

We believe that medical surveillance programs can pro-

vide protection for employees when combined with en-

vironmental control. They offer a valuable tool, in addi-

tion to dust measurement, for evaluation of the effect

of that environment upon employees. They can identify

the employee who has a problem and provide him with

medical assistance and in receiving benefits that are due

him. They can identify the employee who is an increased

risk, inform him, and help him to take necessary meas-

ures to protect himself. Medical surveillance programs

are not a substitute for diligent efforts to control dust.

61

EXHIBIT 6-66

An Epidemiological Study of Respiratory Symptoms

in Lancashire Mills, 1963-66

M.K.B. MOLYNEUX and J.B.L. TOMBLESON

Department of Occupational Mealth, University of

Manchester and H.M. Medical Inspectorate of Factories

Molyneux, M.K.B., and Tombleson, J.B.L. (1970). Brit.

J. industr. Med., 27, 225-234. An epidemiological study

of respiratory symptoms in Lancashire Mills, 1963-66.

An epidemiological study of card and blowroom workers

in 14 cotton spinning and two man-made fibre spinning

mills in Lancashire had been carried out on a prospective

basis of six-monthly examinations over three years. The

number of operatives to be included was decided so as to

give a sufficient sample for the statistical assessment of

fall in FEV, at the same time allowing for population

movement. The examination of each worker included a

history, a questionnaire of respiratory symptoms, and a

measurement of forced expiratory volume in one second.

The results in this paper, which will be followed by

others on other aspects of the surve » give the prevalence

of both byssinosis and bronchitis, according to the defini-

tion given, in the 1,359 cotton workers and 227 man-

made fibre workers, seen at least once, and also the dust

levels in the mills. Eight of the mills processed coarse

and six medium cotton.

The total prevalence of byssinosis, as defined in 26.9%,

being higher in coarse than in medium cotton mills, and

the occupational groups most affected are strippers and

grinders, carders and undercarders, and draw frame

tenters. In coarse mills symptoms develop in some men

and women within the first four years of exposure, and in

medium mills between five and ten years’ exposure. Re-

peat questionnaires in about half the population, two

62

years after the first questionnaire, showed the develop-

ment of symptoms of chest tightness in an appreciable

number not previously affected. The incidence of bron-

chitis is increased in operatives with symptoms of bys-

sinosis, but is influenced by age and smoking.

Total dust levels averaged 3.1 mg/m® in coarse mills

and 1.2 mg/m® in medium mills. The findings indicate

that dust control measures, though they have produced

considerable improvement, are not now fully effective

with present methods of production.

TABLE 3

BYSSINOSIS: PREVALENCE (%) IN POPULATION SEEN

All cotton Man-made fibre

Grats Tide Female. fetal Male Female Total

Yo 6.9 6.7 68 1.0 2.3 18

I 138 12.7 132 31 1.5 2.2

Il 7.6 6.2 68 0.0 0.8 0.4

Total 283 25.6 26.7 341 4.6 4.4

No. 566 793 1359 97 130 227

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64

EXHIBIT 6-73

Schilling, et al., “Cardiovascular Disease in Cotton Workers”

* * —_ o *

Sources of Unreliability in Mortality Rates

Many doctors certify multiple causes of death from

which the Registrar General must select one for com-

puting death rates for specific diseases. The practition-

ers often cannot verify their diseases either by necropsy

or special investigation. Thus both the Registrar Gen-

eral and the general practitioner introduce possible

sources of error into the mortality rates ascribed to

specific diseases. And as the habit of multiple certifica-

tion has become more common in recent years, the secular

trends in the mortality rates of certain diseases may

therefore be seriously misleading.

Multiple Certification—When the medical practitioner

gives more than one cause of death on the certificate the

Registrar General selects one according to certain rules.

In 1921-23 and 1930-32 any definite diseases of the heart

or kidneys was preferred to any disease of the respiratory

system when both were mentioned together. In 1939 the

Registrar General’s selection rules were revised. Prefer-

ence is now given to the disease which, as far as can be

ascertained was, in the opinion of the certifying medical

practitioner, the starting point of the sequence leading

up to the immediate cause of death. The effect of adjust-

ing bronchitis and cardiovascular death rates for 1921-

23 and 1930-32 in the light of this revision cannot be

shown accurately, but it is possible to get some idea of

the likely change from two different sources—the Regis-

trar General’s statistics for 1939 (the year of change),

when he classified all the death certificates according

to both new and old rules, and from a review of the death

certificates of card room workers, applied by the trade

unions. The latter is a source of information often avail-

able but seldom used.

69

The relevant conclusion of the Registrar General (1947)

as regards our particular problem is:

“Bronchitis and asthma death rates have been

affected considerably . . . by the increasing mention

of myocardial degeneration as a contributory cause

of death and consequent classification by the (old)

rules of selection, of increasing numbers to heart

disease.”

He gives conversion factors so that an estimate may

be made of the number of deaths before 1939 from

diseases, of the myocardium among the general popula-

tion which would be put back to respiratory deaths if

the new selection rules applied. For bronchitis in all

males there is added 0.237 times the number of deaths

which were previously ascribed to diseases of the myo-

cardium. But for groups with a high respiratory mor-

tality a higher proportionate transfer should be made.

There is, however, another method available for the very

necessary interpretation of the Registrar General’s rates

of cardiovascular and respiratory mortality before 1939.

But it must be emphasized that it is a highly tentative

procedure. In 1939, when deaths were given classified

under both rules, the bronchitis deaths under the new

classification were increased by transference from dis-

ease of the myocardium, endocarditis, and arteriosclerosis

from amounts varying from 30% at ages 25-34 to 114%

at ages 65-69. If these age-specific conversion factors

are applied at the appropriate ages, the death rates from

cardiovascular causes in 1930-32 are reduced by the fol-

lowing amounts for ages 25-69 (Tables C and E).

ESN Lae 8%

SE Ce 10%

Strippers and grinders ................ 24%

Ee 10%

66

We have assumed that practitioners combined bron-

chitis and heart diseases on their death certificates in

much the same proportions in 1930-32 as in 1939 and

that the practice was similar among practitioners in cot-

ton areas as elsewhere.* We have no means of verify-

ing these two proportions, but if our assumptions are

reasonable, cardiovascular death rates for strippers and

grinders would be reduced under the new system of

classification by more than twice as much as the similar

rates for all males and the other cotton groups.

Death certificates of 256 card and blow room workers,

or known ex-card and blow room workers, of all ages in

the Rochdale, Oldham, and Bury areas, obtained from

the trade unions, were examined. These covered a period

from 1941 to 1948. In Fig. 4 the effect of the change in

methods of classification is shown for the 25-69 age

group in which there were 164 deaths.

Of the 24 additional deaths from respiratory causes

under the new system of classification, 19 were trans-

ferred from diseases of the myocardium, three from

endocarditis, one from “other heart diseases’, the re-

maining one coming from chronic rheumatism. This

transference lowers the cardiovascular death rate for

ages 25-69 by

23

67

This compares with the 24% estimated by the other

method. +

x 100 = 34% **

* As multiple certification continued to increase between 1930

and 1940 we may have overestimated the reduction.

** In addition to transferring 23 deaths from cardiovascular to

respiratory causes, two other deaths were transferred to the cardio-

vascular group from other causes, giving a net loss of 21 deaths as

shown in Fig. 4.

+ For all ages, the transference lowered the cardiovascular death

rate by 30%.

67

Figure 4

se

«

DF

64 CARD AND BLow ROOM WORKERS

SSIFICATION OF CauUSe OF DEATH

!

—_——

I941 - 1948

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O.o SYSTEM New System

oF OF

CLASSIFICATION CLASS! FICATION

[ree 1935] [Posy 1935)

The Registrar General (1949) records that in the

1921-30 decennium 33% of all death certificates for

non-violent deaths gave “multiple” causes. By 1935 this

proportion in all death certificates had risen to 43%. It

is reasonable to infer that there was a substantial in-

crease in multiple certification between 1921-23 and

1930-32, which would mean that a higher proportion of

respiratory deaths would be allocated to cardiovascular

deaths in the latter than in the former triennium. This

may be a possible explanation of the opposite secular

68

trends in cardiovascular and respiratory mortality, and

in fact both these death rates may have been falling.

The North IV (Lancashire and Cheshire) region in

1930-32 showed a mortality excess from respiratory dis-

eases over all males at all ages. Some of the cardio

vascular mortality excess for this region can be similarly

explained. But, even after reclassification by the meth-

ods given above, death rates for heart diseases and

nephritis for males in North IV are still significantly

greater than rates for all males at ages 45 and over, but

spinners and strippers and grinders have higher rates

than North IV at ages over 55 (Table D). These high

cardiovascular death rates for North IV cannot be

explained.

Errors in Diagnosis.—It is not possible to be certain

about the effects on mortality rates of using vague terms

to describe causes of death, or of frank errors in diag-

nosis. The cardiovascular group of diseases includes

myocardial diseases and degeneration which are vague

labels used for diseases in which the exact pathology is

not known. The use of “heart failure” as a cause of

death is not favoured by the Registrar General, and for

these diseases of uncertain pathology in which cardiac

failure is the terminal result, the general practitioner

undoubtedly uses “myocarditis” and the like in order to

avoid enquiries about his certificates.

We have considered the reallocation to respiratory

deaths of certificates on which both cardiovascular and

respiratory causes are mentioned; but it is probable that

there are some death certificates with no mention of

respiratory disease, even though such a disease was the

starting point of the pathological changes leading to death.

And it is also probable that such an event occurs even

t It is of interest that in 1947-8 a similar excess for heart disease

is still present, in spite of the new methods of classification.

69

more often among cotton workers exposed to dust than

among all males or men of the same social class, for rea-

sons which will now be discussed.

Byssinosis has been repeatedly described as a disease

which closely simulates chronic bronchitis and emphy-

sema, but O’Sullivan found that among 33 men suffering

from disabling byssinosis 12 had no clinical evidence of

bronchitis. Shaw Dunn, and Sheehan (1932) did nec-

ropsies on 10 cotton mill workers, nine of whom had been

exposed to dust; while all of these nine had some evi-

dence of chronic bronchitis and emphysema, six showed

hypertrophy of the right ventricle, four of whom died

of congestive cardiac failure. Thus cotton workers with

disabling byssinoisis, with its characteristic asthmatic

symptoms, may present a clinical picture of cardiac

asthma or congestive cardiac failure, which so masks

the respiratory disease that it is not mentioned on the

death certificate.

For nephritis it is possible to make more definite

assumptions about mistakes in diagnosis.

Platt (1947a) suggests that most of the deaths as-

signed by the Registrar General to nephritis in the older

age groups are not renal deaths at all. In his own 161

cases for which full records were available, the main

incidence of deaths from nephritis was under the age

of 45. The Registrar General’s figures for age incidence

are totally different, with the main mortality over the

age of 45. Platt’s own experience is that many cases

of hypertensive cardiac failure with albuminuria are

diagnosed by their general practitioners as chronic in-

terstitial nephritis.

Nephritis death rates are particularly high in certain

occupations. Greenwood and Russell (1988) showed that

in the 1921-28 triennium the textile trades, pottery dip-

pers and file cutters, all of whom had high nephritis death

70

rates also had a high risk of dying from respiratory

disease.

For all occupations there is a significant correlation

between the standardized death rates for bronchitis and

nephritis in 1921-23 (Table 2). In 1980-32 the same

type of occupations appear to have high nephritis death

rates—blow room workers and foremen, strippers and

grinders, and cutlers—but for this period, as shown in

Table 2, there is a significant correlation between the

standard mortality ratios of bronchitis and nephritis only

for Social Classes III and IV. A possible explanation for

this relationship is that many of the men in these trades

died of congestive cardiac failure caused by respiratory

disease and were certified as nephritis deaths.*

Thus there is some evidence that medical practitioners

may fail to distinguish renal disease from other dis-

eases which in their terminal stages simulate renal

disease. It seems possible, therefore, that the mortality

excess from nephritis in cotton workers may be due to

deaths from respiratory disease, which terminates as

congestive cardiac failure. If, however, occupational in-

fluences cause hypertension, as has been suggested, there

will be another reason for high “nephritis” death rates

in cotton workers.

Conclusions

In order to get a clearer picture of any occupational

mortality excess due either to cardiovascular and respira-

*In the same paper Greenwood and Russell drew attention to

the high nephritis death rates in barmen and inn and hotel keepers

for whom an excess of alcohol is probable. In the triennia 1921-23

and 1930-32 there is a significant correlation between standardized

death rates for nephritis and cirrhosis of the liver. It is possible

that this correlation is due to some cases of cirrhosis of the liver

which terminally have oedema being misdiagnosed as nephritis.

Fishberg (1939) quoting his own experience and that of others is

very sceptical of the role of alcohol in producing renal disease.

_.

71

tory diseases for the triennium 1930-32, cardiovascular

and respiratory deaths are given in Fig. 5, added to-

gether, for the cotton trades, for all males, and for males

of similar social classes to the cotton workers. The occu-

pational hazard of the cotton trades, particularly of the

stripper and grinder, is obvious. We know that most of

this is respiratory and that in the past respiratory mor-

tality of cotton workers has almost certainly been under-

estimated; but when a correction is attempted for the

respiratory deaths allocated to the cardiovascular group

of diseases, there still seems to be an excess of deaths

for the cotton workers and particularly so for the strip-

pers and grinders. Thus there may be a real excess of

heart disease due to occupational influences. The latter

possibility is so important in view of the very high na-

tional death rate from cardiovascular diseases and the

absence of information on its relation to environmental

factors that this clue must be followed up. As Morris

(1951) said, cardiovascular disease of middle and old

age is one of the darkest areas of vital statistics and at

present the main source of information must be the

mortality rates. In another paper the results of a clinical

investigation of more than 300 men employed in cotton

textile mills will be described.

TABLE 2

CORRELATION BETWEEN NEPHRITIS AND BRONCHITIS

(AGEs 20-64 YEaRs)

Nephritis and Bronchitis rT No. of Groups P

1921-23* 38+ .04 164 P<.001

1930-32+ .22+.12 71 Not significant

1930-32 .44+.13 59 P<.01

(Social Class III-V)

*From Registrar General’s Decennial Supplement, based on

C.M.F.’s of all trades and referring to chronic nephritis only.

+ Based on S.M.R.’s of trades with 10 or more deaths, and refer-

ring to acute and chronic nephritis.

72

Figure 5

DeatH RATES IN 1930-32

2

A

DEATHS FROM NEMIRITIS, CARDIOVASCULAR

B

+60 CARDIOVASCULAR DEATHS LESS AN CSTIMATED

®ND RESPIRATORY OISEASES NUMBCK TRANSFERRED TO RESPIRATORY CAUSES

AS GIVEN IN THE R.G.3 DECENNIAL SUPT oT THROUGH CHANGED METHODS CF CLASSIFICATION

+T 5°

Act MAMLED x=

Sem. cusss Or FL

Soca, Cosss OF SS

Weavaes =. + 40

SPimm ees =.

Semrrcas £ Cunoeas FQ

sa 2

=

5 +20

=

=

= +10

a =

no” => bh.

7 = = oo,," v

FN Fe : . 2

NSS = LL EYN TS &

45- 65-69 pe 45

Figures above columns for coulion workers arc number of deaths upon which rates ure bused. (See Appendix, Tables C and E.)

Summary

Since 1891 the Registrar General has recorded high

death rates from cardiovascular diseases among cotton

workers.

It has been suggested that this mortality excess may

be due to hyperpiesis caused either by the inhalation of

textile dusts or by inbreeding in Lancashire cottun towns.

In this paper the Registrar General’s figures are ana-

lysed principally for the triennium 1930-32 (the last to be

published). It is shown that in the three occupational

groups studied, strippers and grinders, weavers and

spinners, there is an association between mortality and

the extent of dust exposure.

The significantly high death rate of the strippers and

grinders (the occupation with the highest dust exposure)

from cerebral vascular lesions supports the hypothesis

73

that hyperpiesis may be the cause of this mortality

eXcess.

Two sources of unreliability in mortality rates are

discussed. (1) Since 1920 medical practitioners have

entered multiple causes of death with increasing fre-

quency on death certificates. The Registrar General makes

rules for selecting one cause of death from certificates

with multiple causes. Before 1939 these rules exaggerated

cardiovascular mortality and reduced respiratory mor-

tality. Since 1939 more reliable methods of selection have

been used, and some of the cardiovascular mortality of

cotton workers who it is known have high respiratory

death rates from byssinosis can be explained simply by

methods of book-keeping. (2) The use of convenient

though vague terms such as “myocarditis” to describe

causes of death, and errors in diagnosis, particularly of

nephritis in the older age groups, may also exaggerate

cardiovascular death rates.

When all possible corrections are made for the exag-

geration of cardiovascular mortality through the errone-

ous allocation of respiratory deaths to it, there still re

mains an excess of cardiovascular mortality particularly

for strippers and grinders. This may well be real and

may be due to occupational influences.

We should like to thank Dr. J. N. Morris of the Social Medicine

Research Unit of the Medical Research Council, Dr. W. P. D. Logan

of the General Register Office, Mr. G. Hart of Rugby Mill, Hollin-

wood, and our colleagues inside and outside our Department for

advice and criticism; Mr. A. Robertson, Mr. H. Chorlton and Mr.

J. Meadowcroft of the Card and Blowing Room Operatives and

Ring Spinners Association.

74

EXHIBIT 6-76

Research Triangle Institute, Technological Feasibility

Assessment and Final Inflationary Impact Statement

‘Table I-6. Total Installed and Annualized

Compliance Costs: -all Sectors

(Costs in Millions of Dollars)

Industry Exposure .|Install-| Annualized [Direct Energy —

Sector Limit ed Cost Capital Operating |Cost {| Annualized

(mg/m) Charge Cost | cost

Yarn Production | 0.5 211.8 33.8 6.9 20.6 61.5

0.2 984.4 158.3 15.6 67.9 241.6

0.1 2,802.7 450.6 ra 147.0 620.6

Cotton Ginning 0.5 16.9 2.7 4.9 1.8 9.4

0.2 292.2 47.0 13.2 30.3 90.4

| 0.1 343.6 55.2 14.7 35.4 105.3

Cotton Weaving 0.5 9.1 1.5 1.7 0.6 3.7

0.2 1,387.9 223.1 40.7 86.3 350.1

0.1 3,939.1 633.2 112.6 245.1 990.9

Waste Processing | 0.5 17.3 2.8 2.6 2.5 7.9

0.2 32.0 5.2 2.9 4.7 12.8

0.1 56.1 9.0 3.4 8.2 20.6

Total 0.5 255.1 40.8 16.1 25.5 82.5

0.2 2,696.5 433.6 72.4 189.2 694.9

0.1 7,141.5~- {1,148.0 154.0 435.7 1,737.4

* * +. * a

III. BENEFITS OF THE PROPOSED STANDARD

1. Introduction

This chapter identifies occupational groups exposed to

cotton dust, discusses the inherent problems of benefit

estimation, and estimates the benefits expected to result

from implementation of the proposed standards. Yarn

preparation workers and other cotton industry workers

are discussed separately herein.

2. Occupational Groups Exposed to Cotton Dust

Two large groups of workers known to be exposed to

cotton dust are considered in this evaluation. They are:

75

1) yarn preparation workers, and 2) workers engaged

in weaving, ginning, cottonseed oil milling, and industries

using cotton waste.

a. Yarn Preparation Workers

In August 1971, 338,310 production workers were

employed in cotton and man-made fiber mills* in the

United States according to a Bureau of Labor Statistics

(BLS) survey [1]. Cotton mills employed 193,014 pro-

duction workers, while man-made fiber mills employed

145,296 such workers. Of the total production workers,

an estimated 22,609 were employed in bleaching, cloth

dyeing and finishing, and fabricating departments; hence,

they were not considered part of the regular textile

operations work force. The regular textile operations

work force then becomes, by subtraction, 315,701.

At the time of the BLS survey, slightly less than one

half of the industry’s production workers were employed

in mills manufacturing all or most of their products

entirely of cotton fibers and approximately one-fifth were

in mills manufacturing products of cotton and man-made

fibers (blends). The balance of the production workers

(thirty percent of the production work force) were em-

ployed in mills manufacturing all or most of their prod-

ucts entirely of man-made fiber.

The BLS survey estimated the number of workers in

cotton mills and all textile mills by selected production

occupations. The estimates for cotton mill yarn prepara-

tion workers were excerpted without change from the

BLS report and are shown in Table III-1. The numbers

of yarn preparation workers in blend plants, also shown

in Table III-1, were obtained by multiplying the BLS

estimates for all textile mills by 0.2 (the fraction of

* Includes SIC 2211, Weaving Mills, Cotton; SIC 2221, Weaving

Mills, Manmade Fiber and Silk; SIC 2281, Yarn Mills, Except Wool;

SIC 2282, Throwing and Winding Mills; and SIC 2284, Thread Mills.

76

workers in mills manufacturing products of cotton and

man-made fibers). Maintenance and miscellaneous worker

estimates for both cotton and blend mills were prorated

from figures for all textile production employees. The me-

dian dust concentrations assigned to the severa] produc-

tion occupations listed in Table III-1 are from Merchant,

et al. [2], and are measured dust levels from six cotton

mills and eleven blend m*'ls. The dust samples were of

approximately six hours duration and were collected with

the Lumsden-Lynch vertical elutriator.

Inspection of Table III-1 reveals that 105,193 and

21,230 yarn preparation workers are exposed to cotton

dust in cotton and blend mills, respectively, and are at

risk of developing byssinosis.*

* * * * s

A commonly used measure of the benefit of health

programs is the value of future earnings lost due to

premature death. Since byssinosis rarely appears as a

cause of death on a death certificate, and further, since

the relationships are not well defined between cotton dust

exposure, byssinosis, and chronic bronchitis-emphysema

deaths which are more commonly recorded, lost earnings

due to premature death could not be calculated. While

excess mortality ** due to bronchitis and pneumonia has

been observed in English workers exposed to cotton dust

[8], it has not been seen in the limited number of studies

of mortality in the U.S. textile industry. Thus, Enterline

and Kendrick [9] studied 6,281 white male cotton textile

workers aged 15 to 64 as a control population in an

examination of mortality in asbestos workers. Using the

U.S. white male population as the standard, a Standard-

ized Mortality Ratio (SMR) ([Observed deaths/Expected

* Office and yarn dyeing workers are not included.

** More deaths than would be expected in a given population dur-

ing a given period.

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A

Tale T11-2.

Other Workers Exposed

to Cotton Oust ahd Assuncd [zposures

Assumed Esposure

Nuaber e }

sic Title a Workers Cpoeration Oust Concentration (wg/a°) Method Country Reforerce

0724 — Cotton ginning 40,436" gin stand 1.05 (medtan) vertical U.S.A. r)

elutrlator

baling press 0.48 do éo ¢o

other 0.59 do 6o eo

overall 0.67 do do 6o

2074 = Cottonseed of mills soo® seed house 73-$90 total dust filter thimble Egypt 4

linter 5-18 de Greenburg- Australts s

Saith impinger

baler 20-37. de do

221 Veaving mills, cotton slashing and warping 1.0-1.03 feedtan) vertical U.S.A, 2

- es elutriator

4 weave rous 1.0-1.09 do do do

83,216 cloth roca 1.0-1.09 do do do

pa incenance 1.0-1.09 do éo éo

2221 Weaving mills, sansude slashing and werpthg 1.0-1.09 do éo an 2

fiver and silk weave roca 0.59 do do Je

cloth room 0.59 do co eo

maintenance 0.59 do do 60

224) Marrow fabric mills 23,500 weave room, blend afl! 0.89 do vertical U.S.A, 2

: elutristor

weave rous, cotton af}! 1.0-1.09 do ¢o vo

2293 Paddings and upholstery 3,500 garnett roos 6.06 (mean) éo ¢o +

fillings

2294 Procesied teatlle waste 3,100 sorting 6.5) (respirable horizontal Toyrt 7

‘ éust) elutrisetor

fiber loosening 6.84 do do 6o

carding . $.02 ¢o do do

splaning 1.12 eo vo

felt processing 3.20 de 6e 60

2296 = Tire cord and fabric 2,214¢ weave roca 0.59-1.09 (medtan) vertical U.S.A, 2

: elutristor

2658 Mattresses and bed- 23,200 gernett roca 6.06 (mean) o U.S.A. ]

springs tepe edge 0.36 do éo 40

quilt 0.28 do .& do

boa spring 0.43 @& 6o 6o

hand tie and 0.24 do do oO

coll tack

everall $.02 do do bo

&@ Odtelned from 1972 Census of Manufactures unless nutet otherwise.

bd If a ain crew ts 12.5 workers (Mattonal Cotton Courcil), then tn 1972 there would have been 12.5 workers/gin X 3.517 active gins

* 43,953 workers. Wowever, 8 percent (3,517) of these are assueed te be office workers, Wence, the workers exposed to.cotton .

Gust fs estimated as 40,446, ;

¢ Twenty percent of production exployees (4,500) Is assume! based on conversations with {ndustrial representative. ¢

e@ Estrured.

ot 1977, Part § Cottua

79

deaths] X 100) of 59.4 was calculated for respiratory

disease, indicating that respiratory disease mortality in

white male cotton textile workers is less than that of the

U.S. white male population. This finding was confirmed

and extended in a recent analysis [10]. The results of a

study of mortality in female cotton textile workers re-

ported by Daum, et. al. [11] are suggestive of increased

emphysema deaths. Given the large number of female

workers in the cotton textile industry (about 55 percent

of the work force), it is especially unfortunate that hard

mortality data are not available. SMR’s for chronic

bronchitis and emphysema in both male and female cot-

ton textile workers would be especially appropriate for

use in this analysis; unfortunately they are not avail-

able at this time.

* o * * *

4, Engineering Controls

Engineering controls are defined herein as substitution

of a less toxic substance for a more toxic one, modifica-

tion or isolation of a process, or local or general exhaust

ventilation for the purpose of reducing or eliminating a

worker’s exposure to a potentially harmful substance.

Thus, dust concentrations in the textile industry may be

controlled by modification of the dust-producing processes

or operations, or removal of the dust from the environ-

ment by ventilation.

a. Yarn Production

1) Process Modification

The yarn production process is essentially one of fiber

cleaning and alignment with the desired goal of remov-

ing all material in the cotton except mature fibers, which

are then spun into yarn. The dust associated with cot-

ton processing is thus an unwanted residue which is

inherent in the operation. Textile processes have changed

80

little over the past several decades although there have

been modifications of some operations, primarily to in-

crease productivity; hence, process modification, other

than improved maintenance, has had little effect on dust

concentrations. The design of high speed cards did re-

quire substantially improved dust capture to avoid pro-

duction problems arising from the larger volume and

greater agitation of materials being processed. On the

other hand, open end spinning, which eliminates roving,

may produce more dust than ring spinning.

Decreasing machine density in a work area, which is

mentioned in the literature as a means of reducing ex-

posure, does not, in fact, reduce the concentration of

dust in the room air. Area dust levels would build up

more slowly in the larger volume of room air, but would

eventually reach the same equilibrium levels if. other

controls were unchanged. This technique is, therefore,

felt to offer little to the solution of the problem of dust

control in the textile industry. Replacement of older,

low-speed production equipment with more modern, high-

speed machines can: reduce the generation of dust. How-

ever, very fine yarns cannot be produced by the higher

speed equipment, so replacement is not a universal solu-

tion. Only in instances where large amounts of lower

quality yarn are desirable would replacement be ap-

plicable. Presently, process modification appears to be

a feasible but limited alternative for dust control [2].

2) Ventilation

The capture and removal of dust from the air at the

point of generation (i.e., local exhaust ventilation) ap-

pears to be the most efficient method of dust control at

the present time. Effective dust removal in cotton process-

ing areas depends on two factors: capture devices located

as close as possible to the point of dust generation and

efficient filtration methods [2]. Considering only the tech-

nological feasibility of efficient capture devices and filters,

81

the scope of ventilation control at the dust source could

range from complete enclosure of each machine (including

total enclosure, ducting, and filtration) to application of

local exhaust ventilation hoods and ducts and adequate

collection devices.

Most older textile equipment has very few enclosed

dust generating points. When local exhaust ventilation

systems are included, they are usually retrofitted devices.

The efficiency of these devices can be improved signifi-

cantly by providing as much enclosure of the machine as

practicable. By confining the contaminant to a smaller

volume, air flow requirements, and hence, energy costs

are reduced. Since the air volume required for the major-

ity of the dust capture devices is directly proportional

to the capture distance, a reduction of one-half of the

capture distance results in a corresponding decrease of

one-half of the air volume required, and hence, corre-

sponding reductions in energy requirements. Many of the

more modern machines are well enclosed and are equipped

with dust capture devices as a standard feature.

There is little variation in the physical configuration

of the capture devices required to attain the levels of

control ranging from 1.0 to 0.2 mg/m*. Vendors of

exhaust ventilation systems currently prefer to add dust

capture pickups, filtration devices, and/or increase air-

flows to reach desired room concentrations.

The level of dust control effected is generally related

to the number and design of local exhaust hoods, air

volumes, and the number of filter Stages through which

the contaminated air passes. By employing a sufficient

number of well-designed dust capture devices (e.g., hoods,

slots, and plenums), sufficient air volumes, and efficient

single-stage filtration, dust levels in the range of 1.0

mg/m* (total dust) can generally be expected in the

working environment; with two-stage filtration (and air

washing) , levels not exceeding 0.5 mg/m® (V.E.) may be

82

expected; if efficient third-stage filtration is added (and

air washing), workroom dust concentrations should not

exceed 0.2 mg/m* (V.E.) fcr an eight hour time-weighted

average (TWA) for yarn-producing mills. Controls to

comply with a 0.1 mg/m?’ (V.E.) level of control are cur-

rently technologically feasible, but may require complete

equipment enclosure and stringent three-stage filtering of

both recirculated and make-up air in the ventilation sys-

tem since dust in the ambient make-up air may on occa-

sion exceed 0.1 mg/m* (V.E.).

Control of cotton dust concentrations in the yarn manu-

facturing industry to levels as low as 0.1 mg/m* (V.E.)

thus appears to be technologically feasible by application

of existing technology. This assessment is based on

RTI’s understanding of the processes and operations in-

volved, the amount and velocity of particle release from

various dust generation points, and the general capabili-

ties of current engineering controls. It appears that con-

trol of dust levels to meet the 0.1 mg/m exposure limit

will require: (a) complete enclosure of openers and

pickers, cards, draw frames, combs, roving frames and

spinning frames with air exhaust; (b) filtration of the

exhaust air from the enclosures to levels approximating

0.1 mg/m*; (c) recirculation of the filtered exhaust air

through the central air conditioning system, where addi-

tional cleaning takes place; and (d) filtration of air con-

ditioning make-up air to a level not exceeding 0.1 mg/m’.

Such a system is conceptually feasible although no em-

pirical verification can be provided since it apparently has

not been tried in any installation. The configuration of

the enclosures may be expected to provide the greatest

design problems, since it will be necessary to provide

numerous access ports and a means to check for operating

malfunctions either by direct inspection or by automatic

indicators.

83

2) Yarn Processing

Yarn processing is a term used to cover those opera-

tions through which yarn may pass after leaving the

spinning frame. These include winding, spooling, twist-

ing, warping, and weaving, all of which are described

in Appendix A.

Engineering controls are available for four of the five

processes cited above; the exception is weaving. Based

on information obtained from vendors, local exhaust ven-

tilation systems could be used to maintain median dust

concentrations of 0.5 and 0.2 mg/m® in areas housing

these processes. RTI estimates that the 0.1 mg/m* limit

could be achieved by adding filtration of the make-up air

for the air conditioning system to the local exhaust ven-

tilation systems.

Commercially available engineering controls applicable

to weaving processes were not identified and it is, there-

fore, assumed that none exist. Some experimental work

has been done with the concept of using general room

ventilation as a dust control measure in weave rooms.

This basically consists of modifying existing ventilation

systems to produce air currents of such speed and direc-

tion as to capture a portion of the dust emitted from

the weaving process and then liltering the dust from the

air. No information on cost or effectiveness of this con-

trol technique is available.

Although the residue of particles of bract, stem, and

leaf (the material suspected of being the causal agent in

byssinosis) in weaving yarns is relatively very small,

there is substantial evidence that enough exists in the dust

found in weave rooms to pose a significant hazard for

workers exposed over long periods. The bulk of weave

room dust, however, apparently is sizing used to treat

the yarn and the total airborne dust normally will exceed

the 0.1, 0.2, and 0.5 mg/m* exposure limits considered

84

in this analysis, although cotton dust may be only a small

portion of the total.

No documentation of engineering controls for looms

was found in the course of this study. The discussion that

follows is, therefore, entirely speculative. Three kinds

of engineering controls may be suggested. Perhaps the

simplest and most obvious is to isolate the weave room

from other dusty areas. It was observed that in inte-

grated mills the doors connecting the weave room with

yarn production areas may stand open during production,

with substantial dust drifting into the weave room.

Elimination of such a dust source is easy and poses no

cost penalty. Similarly, room ventilation systems should

be separated so that dust is not introduced through recir-

culation from dusty areas.

The room ventilation system may be the primary

means of lowering dust concentrations in the weave room.

A very high air flow through the room, combined with

high efficiency filtration, would appear to be appropriate.

The use of floor vents drawing air at high rates from

under looms may also be used. Another engineering con-

trol technologically feasible for control of most looms,

apparently is local exhaust ventilation. It is probabie

that hoods can be installed above most looms and that

quite high rates of air flow can be employed to capture

dust released from the loom or blown off by travelling

cleaners where they are employed. Without knowing the

range of possible specifications for air flows or distances

from hood to dust source (which would require specific

preliminary design analysis), it is not possible to estimate

the collection efficiencies that can be attained with local

exhaust ventilation. Air filtration is less difficult to con-

ceptualize, since high efficiency can be achieved with

multi-stage filter systems.

Good housekeeping procedures provide one other obvi-

ous control measure that can contribute significantly to

85

maintenance of low dust levels in the weave rooms. Care-

ful and thorough cleaning of the room weekly to remove

accumulated dust from equipment and from the room in

general tends to prevent the build-up of excessive dust

levels. This should be done at a time when production

is shut down.

The aggregate effect of a combined control program

such as discussed here is hard to estimate. RTI engineers

are of the opinion, however, that such a program may

reasonably be expected to achieve an exposure limit of

0.2 mg/m*® TWA. It is not clear whether a limit of 0.1

mg/m* can be attained in this way.

* * * * *

b. Reduction of Workers Exposure: Yarn Production

Mills

A wide range of engineering controls are technologically

feasible to control dust levels in yarn mills. The industry

naturally has chosen methods that are most cost effective.

The controls specified herein as most probable for com-

pliance with the proposed standards are those now in use,

modified to achieve the required efficiencies. Their feasi-

bility has been demonstrated and they are readily avail-

able from vendors. These controls reduce the dust con-

centration in the work area by capturing and removing

the dust as it is generated through the use of local

exhaust ventilation on production equipment. A typical

system consists of dust capture devices (such as hoods

or enclosures over dust emission sources) , ducts for trans-

porting the contaminant, and a filtration system for ¢iimi-

nating the dust from the airstream. These systems are

discussed in Chapter IV and Appendix A.

Basically, the physical configuration of local exhaust

ventilation systems is independent of the dust concentra-

tion considered. However, differences do arise in the

additional stages of filtration required to control at the

lower dust concentrations and in the dust capture devices

and air volumes. The plant areas in which the systems

86

are employed also affect the control strategy required

to comply with different levels of control. To achieve

dust concentrations not exceeding 1.0 mg/m’, it is as-

sumed that local exhaust ventilation systems are now

employed on opening, picking, carding and drawing opera-

tions and that a single stage of filtration is used. To

achieve dust concentra.ions not exceeding 0.5 mg/m!

(V.E.), RTI’s analysis indicates that, in addition to the

above operations, local exhaust ventilation will also be ap-

plied to combing, roving, and spinning operations and

that two stages of filtration will be employed. To achieve

dust concentrations not exceeding 0.2 mg/m® (V.E.),

these data indicate that ventilation systems will be ap-

plied to the same operations with a third stage of filtra-

tion added, consisting of either an electrostatic precipita-

tor or a high efficiency bag filter. Control to the 0.1

mg/m* limit requires enclosure of equipment, exhaust to

high efficiency filters, and filtering of air conditioner

make-up air.

In addition to engineering controls, a program to re-

duce worker exposure through improved specific work

practices designed for each work position will be insti-

tuted. Although no specific modifications in work prac-

tices are suggested, for costing purposes it was assumed

that a study of the work practices for a total of 21 work

positions will be instituted by firms in the industry to

identify possible improvements and workers will be given

appropriate training based on the findings of the study.

The type of work practice changes that may be instituted

are discussed in Chapter IV.

During cleaning operations and certain other opera-

tions, such as waste collection and bale opening, which

require manual handling of cotton fiber, the described

ventilation controls are not adequate to maintain the

exposure of the individuals involved in these operations

at acceptable levels (see Chapter IV). Therefore, the

probable methods of compliance include the use of per-

87

sonal protective devices for these individuals. Specifically,

it is assumed that respirators are used by all individuals

involved in blow down, stripping, grinding, dry sweeping,

and manual trash collection. It is also assumed that

disposable respirators are the most probable choice of

the industry.

* x € * *

4. Compliance Costs

Costs associated with the implementation of controls

to attain proposed cotton dust standards fall into two

general categories:

® costs associated with the installation/operation of

engineering controls

© costs associated with ancillary programs, e.g.

medical surveillance, environmental monitoring,

respirators, recordkeeping, and training.

All of the cost estimates shown are calculated as the

incremental costs required for compliance with the pro-

posed cotton dust standards, at alternative dust exposure

levels. It is assumed that the existing regulation limiting

worker exposure to dust concentrations not in excess of

1.0 mg/m* (TWA) applies to yarn production and

processing industries and that for these industries there

is no incremental capital cost for engineering controls

to comply with an exposure level of 1.0 mg/m* (TWA).

At the time this study was performed it was evident

that not all firms were, in fact, in compliance with the

existing regulation, although the actual level of controls

operating in the cotton yarn industry could not be deter-

mined. In order to provide a reference point for the

incremental costs presented in this report, the costs of

going from zero dust control to compliance with the ex-

isting 1.0 mg/m* exposure standard was estimated at

$143.3 million, in 1974 dollars.’ Other costs associated

with additional requirements of the 1.0 mg/m* standard

scenario, such as medical, posting, personal protective

7%

88

equipment, employee information, work practices, and

monitoring and recordkeeping are addressed and are

shown in the appropriate sections.

There is some ambiguity regarding the application of

the existing regulation to the other industries for which

costs are shown. It is Department of Labor policy that

no regulation will apply to an agricultural operation un-

less it is so stated explicitly in the regulations. Since

cotton gins are not explicitly covered by the existing reg-

ulations, it is assumed that industry is not covered. It

appears that the cotton waste processing industries and

the cottonseed oil industry have not been required to

comply with the existing regulations although it might

be construed technically to apply to them. For this analy-

sis, they were not assumed to be in compliance with the

current standard.

Costs associated with compliance at the 0.5, 0.2 and

0.1 mg/m*® (TWA) (TWA) are shown as the increments

required for compliance at those exposure levels assum-

ing compliance with the current regulations, where

applicable.

a. Yarn Production

1) Engineering Controls

For engineering controls, capital costs include the pur-

chase price of the control systems, labor and materials

required for the installation of the control systems, and

costs associated with building and utilities modification

required for the installation of the control systems. Oper-

ation and maintenance costs include the labor and mate-

riais required for the day-to-day operation of the control

system, including repair parts and filter replacement.

Energy costs, expressed as kilowatt hours, are reported

separately and reflect the incremental increase in energy

consumption resulting from the operation of the control

system and the increased load on existing air conditioning

systems. Additional labor requirements (man-hours) to

operate and maintain the control system are also pre-

—

89

sented. These cost elements are integrated in estimating

annualized costs in the economic analysis of Chapter VI.

Engineering costs were initially computed on the basis

of cost per cubic foot per minute (CMF) of air required

to control dust generation from yarn production and

processing equipment. These were then converted to a per

machine basis, and subsequently to a cost per pound of

raw cotton processed through the equipment. Data used

in determining costs were obtained from control system

vendors, textile plants in which control systems are in

operation, and from data published by the R.. S. Means

Company pertaining to the costs of various types of con-

struction. Table V-1 contains the basic cost data by

equipment type for yarn mills. Details as to how these

data were developed are presented in Appendix B.

Equipment inventory data were obtained from US.

Bureau of Census publications. Equipment capacities and

throughputs were obtained from various literature

sources. A summary of these data is shown in Table

V-2. Details as to how the data in Table V-2 were

generated also appear in Appendix B.

In order to provide estimates of the cost. of engineer-

ing controls for yarn manufacturing processes to achieve

0.1 mg/m' limits, it was necessary to extrapolate from

the costs for less stringent controls. This procedure is

valid as a means of providing a first estimate of coat

because (a) the control techniques postulated to achieve

the 0.1 mg/m limit are essentially extensions of the

techniques used for lesser control, i.e., ventilation and air

filtration, and (b) the cost data for controls at 1.0, 0.5,

and 0.2 mg/m’, as well as RTI’s experience with similar

controls in other applications, indicates that there is a

reasonably stable functional relationship between control

cost and level of control. Mathematically, this calculation,

for any machine type, is as follows:

where: X = control cost at the 1.0 mg/m® limit,

Y = control cost at the 0.5 mg/m limit,

Z = control cost at the 0.2 mg/m* limit, and

U = control cost at the 0.1 mg/m? limit.

Solving for U gives the expression:

_ 56 (ZY)?

“@ YX

The incremental control cost at the 0.1 mg/m? limit,

therefore, is U - X.

3) Overall Industry Costs

Industry-wide costs, initial and recurring, are shown

in Table V-5. These costs are based on applying feasible

controls on all cotton/yarn equipment regardless of type

of fiber being processed. Exclusion of equipment process-

ing man-made fibers only could reduce these costs by as

much as 30 percent. Presumably, a mill processing syn-

thetic fibers exclusively will not be subject to regulation

under the proposed standard. It is not clear, on the other

hand, just how the proposed standard will be applied in

mills that process both cotton and synthetics. The equip-

ment used in both processes is essentially the same and is

convertible from cotton to synthetics and vice versa. The

conservative estimate was made, therefore, that controls

would be applied to all the production equipment in mills

processing cotton and cotton-synthetic blends, even if part

of their product is pure synthetic.

+Z.

91

Costs per pound of raw cotton are shown in Talie V-6;

manpower requirements in Table V-7. Where a range of

costs is presented, the lower figure reflects the cost of

controlling equipment on which cotton or cotton blends

is processed; the higher figure reflects the cost of con-

trolling all yarn processing equipment regardless of fiber

being processed.

’ . * * «e *

2) Weaving

a) Engineering Controls

Cost estimates for engineering controls for yarn proc-

essing equipment in weaving mills were obtained by

soliciting estimates from vendors of dust control equip-.

ment. Costs were estimated using the same analytical,

steps as described for the yarn production industry (See

p. V-10).

Table V-9 gives the ventilation requirements to control

the median dust concentrations to 0.5 and 0.2 mg/m!

(V.E.), and gives the cost per machine, the annual main-

tenance and operating costs, and the annual energy con-

sumption for dust control systems for the processes indi-

cated. As indicated in Table V-9, no controls are esti-

mated to be required in twisting, weaving and warping

to achieve a median dust concentration of 0.5 mg/m®

(V.E.).

* r * * *

Additionally, based on vendor data, it is estimated that

dust control systems for winding and spooling would be

required in only 20 percent of the installations to achieve

0.5 mg/m* (V.E.). These installations are those in which

the yarn being processed was manufactured from very

low quality cotton or which for some other reason have a

greater than average dust problem. To estimate the cost

per machine for dust control systems, the costs obtained

from vendor data were multiplied by the estimated frac-

tion of installations which would require dust control

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93

systems. Because of this, the cost figures appear quite

low. This method of presenting costs was chosen to permit

total industry costs to be obtained by multiplying the fig-

ures in the table by the total equipment in place. A simi-

lar discussion applies to the figures given for the 0.2

mg/m* exposure limit. In this case, based on vendor

supplied data, controls are estimated to be required in

80 percent of all installations. Installations not requir-

ing controls are those which process yarn made from very

high quality cotton. Consequently, the fraction which re-

quires dust control systems is much greater than for the

0.5 mg/m*® limit. Data on the number of units of each

piece of equipment now installed in the industry, shown

in Table V-10, were obtained from [3] and [4].

Costs for weaving looms are based on engineering con-

trols estimated ‘to be applicable to the operation. For cost-

ing purposes, these consist of local exhaust ventilation

systems over the area of the loom where the shuttle passes

back and forth. It is estimated that a hood for this

application would need to be aproximately two feet by

five feet, based on an |

* * * * a

estimated average loom width of 54 inches. It is further

estimated that an air velocity of 200 feet per minute at

the face of the hood would be needed to adequately cap-

ture the dust, which results in a requirement for 2,000

cfm per loom. The costs per cfm for application of hoods

in such systems are estimated to be about the same as in

the yarn production industry. The figure used for deter-

mining costs was $3.00 per cfm. Using this figure and an

air requirement of 2,000 cfm along with the estimated

209,792 looms [4] processing cotton or blends of polyester

and cotton, a total industry capital cost of $1,258.75 mil-

lion is derived. Annual operating and maintenance costs

are estimated at 3 percent of capital costs, or $37.76 mil-

lion. Energy consumption is estimated at 12.5 Kwh/

94

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95

cfm/yr., which is the approximate average of systems

in the yarn production industry at the 0.2 mg/m* (V.E.)

level. Cost estimates for the 0.1 mg/m® (V.E.) level

were obtained by assuming the increment over the costs

of 0.2 is equal to that determined for the yarn production

industry. The costs obtained for each level are given in

Table V-11.

+ * * * *

The Long-term Arrangement Regarding International

Trade in Cotton Textiles (LTA) provided the vehicle for

import quotas on cotton textiles and apparel and was of

major importance for a number of years. The sharp rise

of man-made fiber products in the late 1960’s led to ex-

panded trade agreements in 1971, and finally to the Multi-

Fiber Arrangement Regarding International Trade in

Textiles (MFA), which dealt with cotton, wool and man-

made fiber products. These arrangements have tended to

smother the effects of a small change in the relative prices

of domestic versus foreign textile products [See Section

10 of Appendix C.I].

* + * * *

4) Impact of OSHA Cost-Related Cotton Yarn Price

Increases

An important intermediate step in determining the

final impact is to determine the impact upon plant

profitability of the different exposure limits. This exami-

nation leads to other considerations such as industry-

wide price increases resulting from control expenditures

and the availability of labor force, energy and capital

for investment in control equipment. Estimations of

potential plant closures also resulted from this analysis.

This analysis relies upon the assumption that the com-

panies affected by the regulations will pass on fully their

increased costs via price increases and thus escape the

cost burden of the proposed OSHA regulation. However,

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97

they would face the contractions of demand for their

products due to price increases.

In order to estimate the potential cotton yarn price

increase, it is necessary to estimate the rates of return

on investment, both before and after new exposure limits,

for each of the six industry sectors. The level of return

on investment after implementation and the relative

change in this level from the pre-control level are the

bases upon which determinations of adverse economic

impact have been made. It is assumed that firms in these

industries will attempt to maintain the pre-compliance

rate of return on investment, and the average price level

in the six industries would increase sufficiently to main-

tain the pre-compliance rate of return on investment.

Two approaches other than the rate of return approach

used here may appear reasonable: (1) raising output

prices in the same proportion as costs increase (a simple

cost pass-through approach) or, (2) increasing output

prices after compliance to the level required to maintain

earnings per share of common stock ( earnings per share

approach). However, the rate of return approach is pre-

ferred over the simple cost pass-through approach be-

cause, as will be shown later, the latter under estimates

the compliance cost-related output price increases, As for

the earnings per share approach, data problems are often

prohibitive. For example, it could not be assumed that

firms in these industries would attempt to maintain

profits per share of common stock, since adequate data

were not available on privately owned small firms.

* ” * * +

Table VI-8 summarizes the estimated change in profit-

ability, measured in dollars per dollar of industry ship-

ments, as a result of incurring three different levels of

exposure limit compliance costs. The first row of Table

VI-8 shows the pre-implementation profitability levels,

which are assumed to be applicable to all six textile in-

98

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Appendix — American Textile Mfrs. Institute, Inc. v. Donovan · 452 U.S. 490 | Frix