Environmental Health Perspectives Supplements101 (Suppl. 2): 199-204 (1993)

A LLabor Perspective on WorkplaceReproductive Hazards: Past History, CurrentConcerns, and Positive Directionsby Tolle Graham,1 Nancy Lessin,' and Franklin Mirer2

The Supreme Court's March 1991 ruling in United Automobile Workers (UAW) versus Johnson Controlsbarring corporate "fetal protection policies" was a major victory for women's employment rights and hashealth and safety implications for both sexes. However, 2 years after the Court's decision, the union's work isfar from over. The UAW has yet to see what policy Johnson Controls will implement in place of the old one.Formulating solutions to the concerns of workers who are exposed daily to reproductive health hazards on thejob will continue to be on labor's agenda. Preventing hazardous exposures is the first priority. This goal wouldbe furthered by setting occupational health and safety standards designed to protect workers' general andreproductive health. Support for the Comprehensive Occupational Safety and Health Reform Act (COSHRA)would also positively affect health and safety in the workplace. Where hazards have not yet been abated, theframework of transfers and income protections for all workers with temporary job restrictions should beexamined. The Legal/Labor Working Group convened at the Occupational and Environmental ReproductiveHazards Working Conference authored guidelines for developing a model reproductive hazards policy. Theserecommendations can serve as a guide for implementation of nondiscriminatory and health-protective policiesby employers.

IntroductionThe Supreme Court's March 1991 ruling in United

Automobile Workers (UAW) versus Johnson Controls (1)was a major victory for women's employment rights andhas health and safety implications for both men andwomen. The ruling struck down Johnson Controls' (1)"fetal protection policy" banning fertile women, regardlessof age or plans to bear children, from working in certainareas of its lead battery plants. In theory, this SupremeCourt decision clears the way for addressing reproductivehealth hazards affecting both sexes without fear thatemployers will simply exclude women from jobs whileleaving men exposed to hazardous substances. However, itwill take concerted vigilance on the part of labor to ensurethat current practices and new policies are truly protec-tive, just, and equitable.

'Massachusetts Coalition for Occupational Safety and Health, 555Amory Street, Boston, MA 02130.

2United Automobile Workers International Union, 8000 East JeffersonAvenue, Detroit, MI 48214.Address reprint requests to UAW Health and Safety Department,

8000 East Jefferson Avenue, Detroit, MI 48214.This manuscript was presented at the Conference on Occupational and

Environmental Reproductive Hazards that was held 20-22 November1991 in Woods Hole, MA.

Unfortunately, in the flurry ofmedia attention followingannouncement of the Supreme Court decision, the centralrole played by labor was often lost in the shuffle. Forexample, this legal action was not the "Johnson Controls"case, as many called it, but the "UAW versus JohnsonControls" case. In 1984 the litigation was brought by theUnited Automobile Workers Union on behalf of all of itsmembers, women and men alike, at UAW-representedJohnson Controls plants. One year after the Court's 1991decision, the union's work is far from over. The UAW isback in court over remedies stemming from the originalcomplaint and has yet to see what policy Johnson Controls,Inc. will implement in place of the old one.The efforts of the American Civil Liberties Union, the

American Public Health Association, numerous labor orga-nizations, the Coalition for Occupational Safety andHealth (COSH) groups, women's and reproductive rightsorganizations, and others who joined as supporters of theUAW in the case greatly contributed to raising publicpressure and awareness about the reproductive health andrights of all workers.

One Union's Experience and a Wordabout Some OthersThe UAW first confronted the issue of exclusionary

reproductive hazards policies in 1976, when one employer

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announced a "fetal protection policy" for lead exposure.Although the policy pertained to only one company, theUAW's International Executive Board debated theresponse, knowing that it would affect the entire union andworkers outside as well.When scientific data were summarized by the UAW's

technical staff, the entire UAW Board was surprised tolearn how little was known about the risks of low-level leadexposure. Although lead has been known as a poison sinceantiquity, there are still few studies examining occupa-tional exposure to lead and reproductive health effects.The clearest evidence in the mid-1970s concerned effectson male fertility. At the time, the UAW even called for astudy by the National Institute for Occupational Safetyand Health (NIOSH) on reproductive health effects ofleadon men in a battery plant. The study took several years,and NIOSH asserted that the results were inconclusive. Adecade later, NIOSH has neither published the finalresults nor repeated the study.The UAW concluded in 1976 that exposure to lead at

levels that then prevailed in the workplace posed a risk toboth men and women workers for reproductive healthproblems and other illnesses. The union also determinedthat "fetal protection policies" were a form of discrimina-tion. These conclusions were communicated to all unionlocals, and the solution called for was cleaning up theworkplace. The UAW position was that any increase inblood lead above pre-employment levels consituted evi-dence of a hazardous exposure at work and warranted allpossible additional protections.The policy at Johnson Controls, Inc. and other battery

manufacturers must be understood in the context ofindus-try's strong opposition to the 1978 Occupational Safetyand Health Administration's (OSHA) lead standard. Thecompany testified against the proposed rule and, throughan industry association, participated in a lawsuit up to theSupreme Court level. Only now has Johnson Controls, Inc.claimed abatement ofpending violations of that decade-oldstandard. In their court papers, the company claimedspecial moral credit for installing control measures toreduce lead exposures, yet these controls were institutedonly after OSHA fined the company and threatened addi-tional penalties for noncompliance.

Other international unions have been confronting theissue of workplace reproductive hazards and policies formanyyears as well. The Oil, Chemical and Atomic Workers(OCAW) played a central role in fighting AmericanCyanamid Corporation's policy excluding fertile womenfrom lead pigment areas of its plant in Willow Island, WestVirginia. A number of women from this plant underwentsurgical sterilization in order to keep their jobs. TheOCAW pursued a legal case claiming that policies pressur-ing women to be sterilized in order to keep their jobsconstituted a violation of OSHA's "general duty clause,"which entitles workers to safe and healthful workplaces.The U.S. Court of Appeals for the District of Columbiaruled against the Union and in favor of the company (2).Later, American Cyanamid closed down its lead pigmentsdivision, and the women who had been sterilized lost theirhigher-paying jobs in that division.

Representatives of the United Steelworkers of America(USWA) remember the ironic events spurred by the pas-sage of the Pregnancy Discrimination Act of 1978. Before1978, company doctors routinely determined that womenworking in steel mills who became pregnant were nolonger fit to work, and these women were immediatelyplaced on leave with no benefits. When the new law statedthat pregnant workers must be treated similarly to otherworkers with disabilities (and therefore given disabilitybenefits), company doctors were suddenly more likely todesignate all pregnant women as "fit to work" throughtheir eighth or ninth month.

Current Concerns: ExclusionaryPolicies

The National Institute for Occupational Safety andHealth estimates that at least 20 million workers in theUnited States are currently exposed to chemicals andconditions on the job that could pose a risk to theirreproductive health (3). The situation where women areforced out of theirjobs because of a hazard to reproductivehealth is not the most common. No matter how importantthe UAWversus Johnson Controls case was, it did not dealwith the circumstances faced by the majority of womenworkers. Most commonly, women workers would like pro-tection from hazardous exposures when they are planningto, or do become, pregnant; there are many more who areexposed to hazards about which they have not beeninformed.For the most part, exclusionary policies have been

implemented in traditionally male industries wherewomen have only recently made gains in employment.Because these jobs are often well paying, there is an amplesupply ofmen readily available to replace women workers.Policies banning fertile women have seldom been imple-mented in traditionally female job sectors, despitenumerous known or suspected reproductive health haz-ards on these jobs. Reproductive hazards faced by womenemployed as health care, day care, or clerical workers,flight attendants, or beauticians include anesthetic gases,ethylene oxide, viruses, solvents, ionizing and nonionizingradiation, ergonomic stressors, and others.Due in part to discriminatory hiring patterns, workers

of color are often placed at particular risk for hazardousexposures, including exposures to reproductive and devel-opmental toxicants. These workers are frequently em-ployed in the most dangerous jobs and occupations andreceive the least pay and benefits. They often have theleast access to information about workplace hazards, arenot afforded adequate protections, and may have nooptions for moving into other jobs or occupations.

Formulating solutions for these concerns is currently onlabor's agenda. By what process will decisions be made todetermine which workers (facing what hazards, at whatexposure levels, on which jobs, and in what industries) willbe left exposed and which workers will be offered protec-tions? What will be the role of management, of the com-

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pany doctor, of OSHA, of the courts, and of labor in thisdecision-making process? Clearly, labor is not willing toleave these issues solely in the hands of management orcompany doctors. Labor has historically been involved in atug-of-war with management over workplace health andsafety. For years, labor has contested discriminatory prac-tices affecting workers' employment opportunities andrights to job safety. Notwithstanding the importance oflegal or legislative victories, this conflict is likely to con-tinue for a long time to come.

Solutions and Nonsolutions

The best solution to the problem of workplacereproductive hazards is to eliminate or reduce hazardousexposures so there is no risk. This goal would be furtheredby setting occupational health and safety standardsdesigned to protect workers' general and reproductivehealth. Where hazards have not yet been abated, theframework of transfers and income protections for allworkers with temporary job restrictions should be exam-ined and improved to accommodate men or women whowant to have children.

Preventing the hazardous exposure is the first priority.Setting occupational health standards that require protec-tion against hazards to the reproductive health of bothsexes is essential. However, there are currently manysituations where the hazard is present now and abatementis months or years away. Labor and public health scientistshave a long list of chemicals for which exposure limits arenot sufficiently protective against reproductive risks, can-cer, and other illnesses. The OSHA standard-setting pro-cess is lengthy and cumbersome, and OSHA has failed toupdate most standards to make them truly health-protective. In addition, the Reagan and Bush administra-tions have been hostile to setting new standards.The use of temporary or permanent transfers until

hazards have been eliminated has been the standard prac-tice of industrial medicine. Transfers from one job toanother and restrictions from certain tasks because ofphysical limitations or increased risk are also routine factsofworking life. However, major problems arise when wageand benefit levels are not retained or when there are nojobs available as transfer options. Workers often fear thatrevealing symptoms of an illness will result in job loss.These issues frequently become components of union con-tracts. Some unions have negotiated independent medicalopinion procedures to address problems of workers whocannot get into jobs because company doctors will not letthem and those who want to transfer off jobs. The newAmericans with Disabilities Act will require job modifica-tions to permit people to work within their restrictions. Itis not yet clear how this legislation will affect pregnantworkers or workers exposed to reproductive hazards.The best approach to this problem is to establish pro-

cedures that accommodate all health problems, risks, orother reasons for restriction and then to fit the specificsituation of exposure to reproductive hazards within that

broader framework. As we examine each aspect of the so-called "fetal protection" controversy, it is evident that thesolution lies in general protective programs, not a "narrowfix."

Unfortunately, in the aftermath of the Supreme Courtdecision, some employers have had a number of disturbingresponses that stray far from reducing hazardous expo-sures and cleaning up the workplace. These responseshave included statements claiming that employers will nowbe "forced" to expose women to harmful substances;threats to "shut down," "move overseas," or "bring inrobots"; requiring workers to sign waivers that releaseemployers from damages resulting from future lawsuitsbrought by damaged offspring; and drafting legislationthat would limit tort rights ofworkers' offspring injured asa result of parental exposure to hazardous chemicals orconditions.Labor will vigorously oppose all attempts by employers

or employer organizations that focus activities away fromcleaning up the workplace, attempt to shift assumption ofrisk back on individual workers, and/or allow employers toshirk their responsibility to provide safe workplaces bylimiting their liability for adverse reproductive outcomes.At the same time, labor will be vigorously promotinglegislation introduced in August 1991 by Senators Kennedyand Metzenbaum and Congressman Ford that wouldreform and strengthen OSHA. The ComprehensiveOccupational Safety and Health Reform Act (COSHRA)has numerous features that would positively affect healthand safety in the workplace (4). The Act would do thefollowing: a) Require employers to establish a program toreduce or eliminate hazards and prevent work-relatedinjuries and illnesses. This program would include provid-ing health and safety training and education to employeesand health and safety committee members. b) Requireemployers of 11 or more employees to establish joint labor-management health and safety committees composed ofan equal number of employee and employer representa-tives. These committees would review employer policies,conduct inspections, and make recommendations for haz-ard control. In unionized settings, the union would selecttheir committee representatives; otherwise, employeeswould elect their representatives by secret ballot. c)Enhance worker/union rights in OSHA enforcementactivities and proceedings. d) Enhance worker rights torefuse hazardous work. e) Enhance antidiscriminationprovisions ("whistleblower" protections) for workers whoreport unsafe or unhealthy conditions and/or refuse haz-ardous work.]) Expedite standard-setting procedures. g)Provide for stronger government enforcement. h) Improvecollection of data for surveillance of work-related injuriesand illnesses and for researching health and safety haz-ards. i) Expand full OSHA coverage to Federal, state,county, and municipal government workers and others notnow afforded full protection under the OccupationalSafety and Health Act (OSH Act). All organizations andindividuals who are concerned with workplace health andsafety, including occupational exposure to reproductivehazards, should join with labor in support of this mostimportant legislation.

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Tough, Unanswered QuestionsThere is still much that needs to change on the shop/

office/hospitaVjob-site floor to make lofty ideals, modelpolicies, and ultimate goals a reality. The ultimate goal ofeliminating all hazardous exposures for all workers is justthat: an ultimate goal. For those workers planning orexperiencing pregnancy who are concerned about ex-posure to known or suspected reproductive hazards, theoption of job transfers without loss of pay, seniority, orbenefits may also be a long way off. In the meantime,interim goals and incremental steps must be implementedthat protect the health and rights ofworkers. Determiningwhat these steps are, how they are formulated, and howthey are attained are immediate tasks for the labor move-ment. This endeavor remains part of labor's role in helpingto secure safe and healthful work environments for allworkers.

Specific RecommendationsRecommendations for EmployersThe Legal/Labor Working Group convened at the

Occupational and Environmental Reproductive HazardsWorking Conference, composed of attorneys, occupationalhealth professionals, and labor representatives, authoredthe following guidelines for developing a model reproduc-tive hazards policy. These recommendations can serve toguide implementation of nondiscriminatory and health-protective policies by employers.

Guidelines forDeveloping a ModelReproductive Haz-ards Policy. PRINCIPLES OF A REPRODUCTIVE HAZARDSPOLICY MODEL. a) It is understood that workplace chemi-cal, biological, and physical hazards may affect all stagesand aspects ofreproductive function, including preconcep-tion damage to the male and female reproductive systems;interference with fertilization, implantation, and thecapacity to carry pregnancy to term; developmental orstructural damage to offspring; interference with sexualfunction; and endocrine system effects as they affectreproductive function. b) Hazards to reproductive healthrequire special attention because they have either beenignored or addressed by employers in ways that discrimi-nate against or penalize workers. An adequate reproduc-tive health policy must be set in the context of acomprehensive occupational health program thataddresses other hazards and risks in a comparable man-ner. c) Reproductive health policies must be appliedequally and without discrimination to women and men andoffer protection to the future children of both. d) As withother health policies, reproductive health policies must bedesigned to protect the most vulnerable segment of theworkforce, consistent with the OSHA mandate that work-places be made safe for all men and women. It is notpermissible to exclude or penalize any segment of theworkforce to achieve these goals. e) Controlling exposureto reproductive hazards is necessary but not sufficient tofully promote worker, fetal, and/or child health. Workersare also entitled to full health insurance, adequate familyand medical leave, adequate pay, job security, and child

care.J) While the need for this model reproductive healthpolicy arises from a history of sex discrimination in theworkplace, there are other important forms of discrimina-tion atwork that must be eliminated. These include, but arenot limited to, the placement of workers of color in thelowest-paid and most hazardous jobs.FEATURES OF A REPRODUCTIVE HAZARDS POLICY

MODEL. a) Hazard determnination: The employer, withactive employee participation, will periodically review allchemicals, biological agents, and physical conditions in theworkplace and determine which ones are known or sus-pected to cause reproductive or developmental harm,including damage to sexual or endocrine function. Deter-mination of risk does not require scientific certainty butmay rely on reasonably suggestive evidence. Employeeparticipation shall be ensured through the establishmentand functioning of ongoingjoint labor-management healthand safety committees. Each employer shall establish asafety and health committee at each worksite of theemployer. The number of management representativesmay not exceed the number of employee representatives.Employee representatives shall be selected by the union(s)representing them; if there is no union, employees shallelect their representatives in an election. The employershall permit members of the health and safety committeeto take such time from work as is reasonably necessary toexercise the rights and duties of the committee, withoutsuffering any loss of pay or benefits for time spent onduties of the committee. Such training as necessary shallbe made available to the health and safety committee. It isnever appropriate to require employees to sign releaseforms, waivers, or indemnity agreements that imply orstate that an employee is aware that she/he is beingexposed to a health risk and that she/he will assume therisk for that exposure, waive rights to bring lawsuits, holdthe employer harmless, and/or indemnify the employer inthe event of a lawsuit.

b) Hazard elimination: The employer, immediatelyupon determining or learning of known or suspectedexposure to reproductive hazards, will take steps to reducethese hazards, with the goal of elimination. Methods toaccomplish this objective include changes in materials,processes, engineering controls or work organization.Whenever possible, this control strategy should includereduced use of toxic materials and redesign of jobs topermit employees to work safely.

During the period before the elimination of hazards,employers will offer voluntary temporary transfers fromjobs that involve exposure to known or suspectedreproductive hazards. These transfers must be available toboth women and men and include full pay, benefits, andprotection of status and seniority. If transfer is infeasible,medical removal protection with full pay, benefits, status,and seniority must be provided.The employer will work with employees and employee

organizations in an effort to remove barriers to the use oftransfer policies such as conflicts with existing collectivebargaining agreements, threats to confidentiality, dis-crimination or other retaliation against workers who usethe policy, and loss of job opportunities.

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Recommendations for Government

The following are recommendations made by the Legal/Labor Working Group for actions to be undertaken bygovernment that will promote jobs and workplaces thatare safe for the health, including the reproductive health,of all workers: a) Appraise reproductive and developmen-tal risks of workplace exposures in all standard-settingactivities and set standards that eliminate those risks.b) Encourage and fund research on the reproductive anddevelopmental risks of chemicals and conditions encoun-tered in the workplace. c) Mandate the reduction of toxicsubstances and provide assistance to employers for their"toxics use reduction" efforts. d) Develop and provideinformation about reproductive hazards to employers andemployees. This would include the addition of reproductiverisks to the adverse health effects section of NIOSH'sPocket Guide to Chemical Hazards (5). e) Issue a state-ment proclaiming that where an employer has had anexclusionary (fetal protection) policy in effect, or hasrequired employees to sign waivers abrogating theirrights to bring lawsuits in eases of reproductive harm,that employer has recognized a reproductive and/or devel-opmental risk and must take immediate action to removethat risk. The Occupational Safety and Health Admin-istration would then cite employers who fail to eomplyunder section 5(a)(1) (the "general duty clause") of theOSH Act (4).

J) Enact the Comprehensive Occupational Safety andHealth Reform Act, with additional language givingemployees rights of private action and prohibiting the useofwaivers. g) Defend existing laws that provide compensa-tion for offspring injury or death resulting from employernegligence or inadequate warnings regarding workplacereproductive hazards. h) Examine and amend existingworkers compensation systems to provide adequate com-pensation to workers for occupational diseases andreproductive disorders, including loss of sexual function.i) Enact reforms that will protect the health of workersand their families such as adequate health insurance for allworkers, parenting leaves, and equal employment oppor-tunities for women and workers of color.

Recommendations for ScientificResearch on Reproductive HazardsWith increased focus on research into the effects of

workplace chemicals and conditions on the reproductivehealth ofmen and women, it is essential that this scientificresearch be carried out in ways that maximize its potentialusefulness and minimize its intrusiveness and possiblenegative consequences. Subjects in this research must beinformed of all study results; workers and unions must beinvolved in all aspects of this research, including par-ticipating in decisions about what is to be studied as well ashow it is to be studied.The United Steelworkers of America have guidelines

governing their participation in research when the union iscontacted by scientists seeking its cooperation. These

guidelines are offered below as a model for all researchersseeking the cooperation of any union or group of workersin their scientific research.

Guidelines Governing USWA Cooperationwith Medical ResearchThese principles are intended to govern situations

where researchers seek the Union's cooperation. Ofcourse, the final decision on cooperation should be made bythe District Director and the Local Union, based in part ona recommendation from the International Safety andHealth Department. The Department's recommendationwill in turn be based on the researchers' willingness tocomply with the following procedures: a) The researchermust supply the Safety and Health Department with awritten protocol for the study. b) Union approval of theprotocol will be based on the following factors: the studydesign should be consistent with accepted principles ofscientific research; the definition and size of the studypopulation should minimize the risk of a false negative orpositive conclusion due to small numbers, insufficientlatency, selection bias, or inappropriate assignment toexposed or control groups; confidence limits should bereported for the results; and research into the effects oftoxic substances on the reproductive system should con-sider both sexes. c) The researcher must agree to rigidethical principles with respect to confidentiality, humanexperimentation, and the necessity and usefulness ofinvasive tests. d) The researcher must supply the Safetyand Health Department with sample copies of consentforms and notification letters to be used in the study. e)The researcher must agree to meet with local unionofficers and the workers to be studied. In most cases, twomeetings will be necessary: one before the study com-mences to explain the tests, and one after the research iscompleted to explain the results. This second meetingshould take place before the results are published orreported to the general public. Additional meetings may benecessary in special circumstances. D) The researchermust agree to report individual medical results to theworkers within 60 days, unless the Union and theresearcher agree on a longer period in advance. Studyresults must be reported within a reasonable time, to bedetermined by the Union and the researcher in advance. g)The Union does not seek the right to modify or forbidpublication ofthe results. Neither will the Union cooperatewith any study where the company is granted that right.Of course, the specific applications of these guidelines toparticular cases are negotiable as circumstances warrant.

ConclusionLabor has received much support from public health,

legal, and other allies over the last decades in fights forsafe and healthful workplace environments and equalemployment opportunities. These alliances are vital to thesuccess of labor's efforts. Recent media coverage broughtpublic attention to an often-overlooked public health prob-lem: safety and health in the workplace, and specifically,

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the issue of damage to workers' reproductive health fromchemicals and conditions on the job.The camera lights have now shifted to other "hot"

issues. Two years after the Supreme Court's decision inUAW versus Johnson Conrols, it is not clear what haschanged for workers in the United States exposed daily toreproductive hazards. It is also uncertain what, if any,imperatives employers are feeling that will compel them toprovide workplaces free of reproductive risk or what legalmechanisms are in place to mandate that they do so. Thesereservations are not meant to downplay the importance ofthe Supreme Court decision, but to highlight the tremen-dous battle that lies ahead to secure safe workplaces forall.When discussions about this topic move away from

academic, legal, or medical circles and into the workplace,there is often less optimism. A cartoon circulated after theSupreme Court ruling showed a woman on the telephonereceiving the news of the UAW versus Johnson Cantrolsdecision and reporting to her husband: "The good news isthat I can go back to work at the toxics plant, and the badnews is that I can go back to work at the toxics plant."The central players in this arena are workers them-

selves, and their perspectives are essential to ongoingdiscussions about workplace reproductive hazards andpolicies. These discussions must be based upon the experi-ences of these workers and focus on the reality of theworkplace. The "front lines" of these battles have been,

and will continue to be, in the workplace. Labor's voicemust guide discussions and actions concerning workplacepolicies, hazard control measures, legislative efforts,research, training, education, and all other areas pertinentto workplace health and safety in general, and workplacereproductive hazards in particular.

We thank Karyl Dunson, Jorge Mujica, and Jim Valenti who joined usto share their own stories and experiences and those of their co-workersat the Labor Perspectives Conference plenary session. We also acknowl-edge Carin Clauss, Marcia Berzon, and Joan Bertin, the coordinators ofthe LegaVPolicy Working Group, for joining forces with the LaborWorking Group in developing the guidelines for a Model ReproductiveHazards Policy and a work plan for promoting real solutions to theproblems workers face from exposure to reproductive hazards on the job.

REFERENCES

1. International Union (UAW) versus Johnson Controls, Inc., 111 S. Ct.1196 (1991).

2. Oil, Chemical and Atomic Workers International Union versusAmer-ican Cyanamid Company, 741 F. 2d 444, (D.C. Cir. 1984).

3. National Institute for Occupational Safety and Health. Leading work-related diseases and injuries- United States. MMWR 34: 537-544(1987).

4. U.S. Congress Comprehensive Occupational Safety and Health ReformAct. S.1622, H.R. 3160.

5. NIOSH. NIOSH Pocket Guide to Chemical Hazards. DHHS (NIOSH)Publication No. 90-117, National Institute of Occupational Safety andHealth, Cincinnati, OH, 1990.