Testimony offered a review of a report submitted by the American Textile Manufacturers Institute (ATMI) dealing with medical surveillance data in the cotton textile industry. The review was restricted to comments on the shortcomings of the methodology used in the study rather than on any of the data presented. The ATMI study used seven member companies for its investigation. The National Institute for Occupational Safety and Health (NIOSH) contended that these seven companies were not likely to be representative of all 200 members of the ATMI or of the textile industry as a whole. The study was actually based on data gathered for compliance purposes and not on a statistically sound strategy which would be essential for making inferences from the study group to the whole population from which the selected study group came. NIOSH also questioned the accuracy of the pooling of data gathered from different sources for compliance purposes and provided several examples where questions arose about the pooling methods used and the completeness of the results thus obtained. NIOSH concluded that, in spite of the large size of the second report by the ATMI, it provided no more illumination of the problem than did the first report and should be disregarded by the Occupational Safety and Health Administration in its rulemaking efforts.
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