Re: comment for RoC procedures meeting

["Michael Eckstein" <Me1065@worldnet.att.net>]

This was from the NTP web site.

National Toxicology Program						"NO" = TCDD NOT HUMAN CARCINOGEN
Board of Scientific Counselors'					"YES" = TCDD IS HUMAN CARCINOGEN
Report on Carcinogens Subcommittee

<P>A. John Bailer, Ph.D.							VOTED "NO"
<BR>Professor
<BR>Department of Mathematics & Statistics            		
<BR>Miami University
<BR>Oxford, OH 45056

<P>Steven A. Belinsky, Ph.D.							VOTED "NO"
<BR>Scientist
<BR>Inhalation Toxicology Research Institute
<BR>Kirland Air Force Base, Bldg. 9200
<BR>Albuquerque, NM 87115

<P>Eula Bingham, Ph.D.								VOTED "YES"
<BR>Professor
<BR>Dept of Environmental Health, ML 056
<BR>University of Cincinnati
<BR>College of Medicine
<BR>Cincinnati, OH 45267

<P>Clay Frederick, Ph.D.							VOTED "YES"
<BR>Senior Research Fellow
<BR>Mechanistic Toxicology Group
<BR>Toxicology
<BR>Rohm and Haas Company
<BR>727 Norristown Road
<BR>Spring House, PA 19477

<P>George Friedman-Jimenez, M.D.						VOTED "NO"
<BR>Assistant Professor of Environmental Medicine
<BR>NYU School of Medicine, and
<BR>Director of Bellevue/NYU Occupational
<BR>and Environmental Medicine Clinic
<BR>Bellevue Hospital, Room CD349
<BR>462 First Avenue
<BR>New York, NY 10016-9198

<P>Stephen S. Hecht, Ph.D.							VOTED "NO"
<BR>Wallin Professor of Cancer Prevention
<BR>University of Minnesota Cancer Centers
<BR>Box 806 MAYO
<BR>420 Delaware Street, SE
<BR>Minneapolis, Minn 55455-0392

<P>Nicholas K. Hooper, Ph.D.							VOTED "YES"
<BR>Head, Research & Methods Development
<BR>Hazardous Materials Laboratory
<BR>Department of Toxic Substances Control
<BR>California Department of Health Services
<BR>2151 Berkeley Way, Annex 11
<BR>Berkeley, CA 94704</TD>

<P>Karl T. Kelsey, M.D.								VOTED "YES"
<BR>Occupational Health Program
<BR>Harvard School of Public Health
<BR>and Medical School
<BR>665 Huntington Avenue
<BR>Boston, MA 02115

<P>Michele Medinsky, Ph.D.							VOTED "NO"
<BR>Toxicology Consultant
<BR>5505 Frenchmans Creek
<BR>Durham, NC 27713

<P>Franklin E. Mirer, Ph.D.							VOTED "YES"
<BR>Director
<BR>Health and Safety Department
<BR>UAW International
<BR>8000 East Jefferson Avenue
<BR>Detroit, MI 48214-2699

<P>Jill C. Pelling, Ph.D.							NOT MENTIONED
<BR>Professor
<BR>Dept of Pathology and Laboratory Medicine
<BR>University of Kansas Medical Center
<BR>3901 Rainbow Boulevard
<BR>Kansas City, KS 66160-7410

<P>Jose Russo, Ph.D.								VOTED "NO"
<BR>Director
<BR>Breast Cancer Research Labs
<BR>Fox Chase Cancer Center
<BR>7701 Burholme Ave.
<BR>Philadelphia, PA 19111

<P>Shelia H. Zahm, Sc.D.							VOTED "NO"
<BR>Deputy Director
<BR>Division of Cancer Epidemiology
<BR>and Genetics
<BR>National Cancer Institute
<BR>6130 Executive Building
<BR>EPN Room 543
<BR>Rockville, MD 20892-7399

<P><B><U>Expert Consultants</U></B>						NO VOTE
<BR>Hiroshi Yamasaki, Ph.D.
<BR>Chief
<BR>Unit of Multistage Carcinogenesis
<BR>International Agency for Research on Cancer
<BR>150 Cours Albert-Thomas
<BR>69372 Lyon Cedex 08
<BR>FRANCE

											7 "NO" & 5 "YES" SAME AS 													OFFICIAL COUNT

Regards,

Mike Eckstein


----------
> From: Tony Tweedale <ttweed@wildrockies.org>
> To: Multiple recipients of list DIOXIN-L <dioxin-l@essential.org>
> Subject: comment for RoC procedures meeting
> Date: Saturday, August 14, 1999 9:09 PM
> 
> Please accept the following comment for discussion at NTP's 15 Sept. '99
> meeting that will consider the review process and evaluation criteria for
> listings in the 8th & 9th iterations of the Report on Carcinogen's (RoC).
> The addendum to the July '99 _NTP Update_ newsletter summarizes such
> comment developed during the listing process for these RoCs, including:
> 
> "* Expand the use of unpublished data;"
> 
> In all instances, NTP procedures should work to ensure data used is as
> valid as possible and does not come from parties who have massive
economic
> interests in having their product or byproduct declared safe.  Just
because
> a party has the money to do many tests and the government, representing
the
> public trust, has little, does not mean NTP should use the data from the
> party with the humongous conflict of interests.  Use of *scientifically
> valid* unpublished data can be of great benefit, so long as, e.g., if it
> comes from the toxin's producer it is independently replicated or
> completely disagregate and each element is verified to be scientifically
> valid.
> 
> 
> "* Involve experts from potentially affected industries in a more
iterative
> manner earlier in the review process;"
> 
> The RoC process (and the NTP generally) should strive to ACHIEVE THE
EXACT
> OPPOSITE!  It is incompetent to think that because a party has any
interest
> they should necessarily help determine public trust decisions regarding
> that interest.  Here the implication seems to be that a producer's
massive
> private, amoral economic interest in its toxin should give it a strong
> voice in the public trust decision!
> 
> In science and elsewhere it is often stated that: "The *appearance* of a
> conflict of interests should be avoided."  Logic shows that an economic
> conflict of interests with the scientific method actually exists *as soon
> as* a person who becomes involved in regulation of that agent is
> subservient to, receives compensation (e.g. salary, pensions, stock
> holdings, contracts) from, or even has certain non-economic attachments
> with, a party with private economic interests in the potential carcinogen
> or otherwise toxic agent involved.  It is not a deliberate conflicted
act,
> but rather simply being in the conflicted situation that determines a
> conflict of interests.  Therefore the strict scientific and moral
standard
> is that no one should be trusted to do the right thing; rather such
> situations should be avoided.
> 
> For example, I see the pending decision on the listing of 2,3,7,8-TCDD
> (TCDD) as a known human carcinogen in the 9th RoC was unanimously
approved
> for further action towards final listing by both NTP RoC Working Groups,
> which I believe are made up solely of government officials and experts;
> whereas the next NTP group working on the listing (the NTP Board of
> Scientific Counselors' RoC Subcommittee), which voted 7-5 against it
being
> listed, is the NTP's *external* peer review group.  Shortly thereafter a
> new, critical piece of epidemeologic evidence was published that added
> significantly to the weight of the evidence that TCDD is a multi-organ,
> multi-species  human carcinogen.
> 
> External peer review is one of the most critical elements of the
scientific
> method, and I am not suggesting 7 members or even 1 member reviewing the
> proposed listing voted against it because they represented economic
> interests who produce or release TCDD.  I do not know who this
> subcommittee's members are.  I am only noting the large vote difference
> between public trust agents (without peivate interests) and the BoC
> subcommittee's presumably varied memebership.  Decision-makers in the
> critical public trust who have economic, even certain emotional or mental
> ties to producers who have *every interest* in making "look, it's safe"
> declarations, means that their decision-making on matters of public
health
> cannot be trusted.  Essentially it's a matter of public vs. private
> interests and motives, but it also violates the essence of the scientific
> method, which demands all relevant factors (not just data) in a question
of
> science be open, competent criticism.  Only out of this severe fire can
> valid scientific decisions in the public trust be forged.
> 
> Billions of workers and others have been poisoned, and certainly
thousands
> have died, because of phenomenal undue industry involvement in the ACGIH,
> which sets what their lawyers call "recommended" ambient occupational
> exposure safe levels (TLVs) to toxins, but that in fact ACGIH industry
> members have successfully lobbied to have adopted as law by countless
> agencies, including the US government and other countries (the TLV
process
> continues to be secretive and heavily influenced by the toxins'
producers.
> At least in the past, TLVs were set simply on current factory floor
levels
> or what the chemical's producer believed it could afford).
> 
> I dearly hope the NTP will throw this suggestion into its wastebasket
> without further consideration, and endeavor to isolate its critical
mission
> and its work from private economic interests.         Sincerely,
> 
> 
> Tony Tweedale
> 224 E. Pine (2)
> Missoula, MT 59802-4541
> 406-542-1709 tel. [& Fax--must call me 1st)]
> ttweed@wildrockies.org
> 
> Causality is a concept not subject to empirical demonstration.
>         -David Hume (1711-'76)
> Temperate but endangered planet.  Enjoys weather, northern lights,
> continental drift.  Seeks caring relationship with intelligent life form.
>       -Friends of the Earth
>