The struggle to free the work process of occupational injury and disease is difficult. Although U.S. workers have made some limited gains relatively recently, industry holds most of the high cards. When the showdown comes, industry pulls out its ace in the hole: “Choose between your job or your life.” Labor is vulnerable to this ultimatum because capital has the ability to buy its labor power from somebody else. Implicit in the choice is the knowledge that somewhere else, somebody will opt for the job regardless of the cost to their health. Testifying at 1972 congressional hearings on the two fiber standard, a vice president of Johns-Manville made the potent threat explicit: Attempting to achieve a standard of two fibers per cc will cost American industry millions of dollars in increased operation costs and unfortunately cause a significant number of jobs to be shifted to foreign workers…We would simply be shifting the problem to other workers in the world, solely because of unrealistic and unnecessary regulations (emphasis added).(1) This statement highlights two crucial problems: that there is good reason for U.S. workers to fear job loss because of occupational safety standards and that contamination of the workplace is increasing throughout the world. Behind both these problems lies the fact that many developing countries have no meaningful occupational health regulations. Studies by the International Labor Organization indicate that non-enforcement of health regulations, alongside low wages, the lack of unionization and military-guaranteed “labor peace” is becoming another card drawing U.S. capital to the third world. A United Nations study warns of the possibility that “a trend might be set in motion to export pollution from the developed to the developing countries.”(2) An OSHA official is more blunt: “The multinational implications of adhering to U.S. standards has in some cases already had the consequence of removing the dirty operations to Latin America and keeping the cleaner part of the production process here.”(3) The purpose of this article is to explore both the possibilities and implications of a shift of hazardous production abroad, especially that of asbestos to Latin America. The possibility that health hazardous industries might escape U.S. regulations by moving production overseas, whether or not they actually do so, threatens the jobs of U.S. workers fighting for a healthy workplace. All too often, this international aspect of occupational health goes undiscussed. The link between conditions in regulated and unregulated countries is not understood by those North Americans who resent the so-called “unfair competition” from foreign workers, or by those Latin Americans who believe that U.S. workers have comparatively little to complain about. Both these attitudes miss the crucial interrelationship. The existence of “unregulated” countries-only a euphemism for totally unprotected workers-inhibits U.S. workers from fighting too strongly for the enactment or enforcement of standards. THE LARGER PROBLEM Let us take a close look at why there are virtually no occupational health regulations in Latin America and how this vacuum lends credibility to the threat of shifting hazardous production abroad. In the first place, the general economic conditions found throughout Latin America and the severity of the economic crisis mean that a job-any job-is precious. For example, the combined unemployment and underemployment rate in Mexico is estimated to be as high as 60%. Such a large reserve army of labor undermines the ability of workers to effectively organize to improve conditions in the shops. As a result, occupational health appears as a luxurious concern. Secondly, endemic and epidemic diseases are so widespread among the general population in Latin America that the importance of occupational hazards tends to be overlooked. The most frequent causes of death in Latin America are infectious diseases and malnutrition. The infant mortality rate is among the highest in the world and in many countries has risen in the 1970’s.(4) OCCUPATIONAL DISEASE Although the general health problems are overwhelming, occupational disease should not be seen outside of them. Quite obviously, if workers are not getting a proper amount of nutrition, they are all the more susceptible to the effects of toxic substances or the more general problems of mental and physical stress due to speedup, noise and the like. These occupational co-factors of disease are largely ignored. Despite the lack of attention given to occupational health problems, some protective legislation has been enacted. In Mexico, for example, the first labor legislation with general worker safety provisions was passed as early as 1936 and further regulated in 1946. These regulations, however, are extremely vague and out of date.(7) No concrete norms have been established subsequently. There is almost no way to ascertain whether or not an industrialist is in compliance. There is virtually no inspection, little consciousness and an absence of mechanisms to enforce even the spirit of the law.(8) The only path left open for workers to obtain workplace protections is to negotiate stipulations in their contracts. Union activity around this issue, however, has been slight. Workers’ efforts to push for occupational safety and health protections have at most resulted in slightly higher pay scales for dangerous work, or an extra liter of milk a day that employers allege will protect workers against dusts or toxins. These measures neither control the causes of health hazards nor provide any cures. These conditions dictate the need for national preventive health plans to attack both public and occupational hazards. Unfortunately, health programs of any type have a low priority in most Latin American countries. Argentina was an exception in the mid-1960’s, with one of the best health systems in the third world.(9) Today, according to one medical expert, Argentina’s military regime “increasingly finds public health an irrelevant concern,”(10) and has even stopped publishing health information. The story is repeated in Chile, where the portion of the national budget devoted to health has declined from 7.2 to 2.5% since 1972, and where only 6% of the population can afford medicines.(11) CAUSE AND EFFECT HARD TO PROVE Because industrial growth is taking place in Latin America without adequate occupational health regulations, the workplace is increasingly becoming the cause of disease. The connection, however, between disease and industry, is often hard to demonstrate. There is a severe shortage of professional and technical personnel with adequate training to even recognize an occupational problem. And those who do notice are under pressure to ignore the connections. In the few places where thorough medical investigations are being undertaken, the likelihood of implementing the findings at the factory level is remote indeed. Evaluating the extent of occupational disease from public records is next to impossible. The only figures available on occupational health come from social security programs, which cover only about 25% of Latin America’s population.(12) Furthermore, the data which does exist refers primarily to workplace accidents and not disease. In Mexico, for example, data is collected by the Social Security Institute (IMSS) which covers approximately four million industrial workers. Its 1976 statistics reveal that some 99.8% of all social security payments were for job-related accidents and only 0.2% for job-related disease.(13) These statistics do not demonstrate a lack of occupational disease, but rather that it is systematically overlooked. TRANSNATIONALS BRING NEW HAZARDS Throughout Latin America it is commonly accepted that the poorest industrial work conditions are found in domestically-owned small and medium-sized plants wher the majority of industrial workers are employed. These shops tend to have the oldest machinery and the most meager health facilities.(14) Hence, many experts conclude that workers are much safer working in the larger plants owned by foreign capital-where more advanced technology and large-scale operations will presumably ensure a healthier work environment. Although these plants may appear to be cleaner and safer, in fact they may be more hazardous than the smaller shops. Transnational corporations in Latin America produce autos, petrochemicals, pharmaceuticals and other products involving the use of carcinogenic or toxic substances. Similar health problems exist in agriculture, where transnational corporations have invested heavily.(15) The increasing mechanization of agriculture in Latin America has been accompanied by the extensive use of synthetic fertilizers and pesticides. FROM WORKPLACE TO ENVIRONMENT Adding to the poor public health and the neglect of occupational disease is another health hazard emanating from the workplace: environmental pollution. All these factors combine and intersect with one another to create a synergistic effect which simply means that the total impact is more deleterious than the sum of its parts. The seriousness of environmental pollution has long been rationalized away with two specious and contradictory arguments. On the one hand, it has been argued that Latin America could learn from the past mistakes of the United States and Europe. On the other, it is argued that since the level of industrialization is lower, environmentally speaking the situation is better; Latin America has a larger “carrying capacity” for pollutants. Both these arguments fly in the face of reality. First, it is a little late to suggest that past mistakes can be avoided, for pollution in many parts of Latin America exceeds that of industrialized countries. Second, the larger “carrying capacity” argument amounts, in only slightly veiled terms, to an open invitation: “Come pollute, we need industry.” In fact, it was Brazil’s position at the 1972 World Environment Conference that developing countries have the “right” to pollute.(18) Aside from what this means for the environment, it totally neglects the intensity of worker exposure and their individual capacity to carry the burden. In fact, poverty lowers the levels at which the Latin American population can tolerate pollution. As Barry Commoner writes, “The most striking effect of air pollution on health seems to occur where a victim’s health is already precarious.”(19) The real reason that the degradation of the environment is permitted and occupational safety and health problems proliferate is the need for industry and jobs. Blanca Ordoñiez, head of the Mexican Environment Improvement Department, made the situation clear: For us a choice exists between eating and getting rid of polluting industries that we don’t particularly like. What we want is clean production. But we can’t inhibit investment because the country is in an economic crisis.(20) Reluctantly it is being admitted that a certain level of pollution and a certain percentage of injured or diseased workers is socially affordable, especially if accompanied by increased industrial investment and given that the effects are slow to show themselves. It is hoped that as long as workers are not dying in the streets, the “social necessities” can be contained. Since the environmental risks originate with hazardous production, workers face the greatest jeopardy both inside and outside the plants. This also means that if the hazards were controlled at the point of production, then the massiveness of the problem would be corrected. But because it is deemed too costly, occupational safety and health remains way off in the distance throughout Latin America. We have shown how the health of Latin American workers is not protected on any front. As modern manufacturing expands, this vulnerability will have even more disastrous effects. Such lack of regulation is a tantalizing lure to U.S. industry, and there is evidence that hazardous production is increasingly moving outside U.S. borders. The cases of benzidine, U.S. zinc mining and smelting, and arsenic production have been cited.(22) As our example, we will focus on asbestos. ASBESTOS ON THE MOVE In asbestos textiles, the case is graphically demonstrated by the operation of a firm called American Asbestos Textile (Amatex). In the mid-60’s, the firm operated several plants in the United States (in Meredith, New Hampshire, Norristown and Milford Square, Pennsylvania) and bought controlling interest in Hilados y Tejidos, a plant in Toluca, Mexico. With U.S. government regulation approaching, Amatex opted for a dual strategy. In its New Hampshire plant, Amatex resisted making the necessary changes to comply with OSHA standards.(23) On the other hand, it closed down the Milford Square plant (opened in 1967) and opened two more Mexican plants just across the border, one in Agua Prieta in 1969 and another in Ciudad Juarez in 1974. Undoubtedly, a central advantage was that workers were paid the Mexican minimum wage. But an added attraction was that these plants could totally avoid the costs of adhering to U.S. regulations. Not only were conditions in the Agua Prieta plant flagrantly abusive of even minimal precautions, but the entire community was exposed to asbestos waste clinging to bushes and fences surrounding the factory, laying in the street scuffed up by children walking to school, brought home by workers on their clothing. No one, except of course the absentee owners of Amatex, was aware that the debris surrounding them was anything but benign. Then, briefly, the lid came off. An Arizona reporter and a former NIOSH official uncovered the existence of the Agua Prieta plant and the dangers were made known to the workforce for the first time.(24) Needless to say the workers were upset and called for an investigation. For a short time it looked as though Amatex would have to pay the consequences for what amounts to nothing short of criminal behavior. But the Children play in loose asbestos from the Agua Prieta plant of Amatex odds against the workers were simply too overwhelming: the entire Mexican border industrialization program exists to attract industry, not to control it.(25) Besides, the effects of asbestos don’t show themselves for many years; the unemployment in the area is conservatively estimated at 22%, supported by a constant influx of workers passing through the border towns in search of jobs; the particular unions function to keep workers passive; and, as we have seen, the Mexican government requires no specific regulations. So after several months, when investigators returned, only cosmetic changes outside the plant had resulted. Essentially the same situation was later uncovered at the Juarez plant by a Dallas television reporter.(26) An official Mexican government investigation was reputedly undertaken but not even the Pan American Health Organization representatives were able to get their hands on it.(27) The results of the scandal now seem to be in: vast numbers of Mexicans will die of asbestos-related disease; the Mexican government will do little about it; and the threat of runaway to avoid OSHA regulation is made vivid and concrete. Half of the Amatex work force is in Mexico,(28) at least half the profits come from there and, by 1975, textiles from Amatex border plants accounted for one quarter of all U.S. imports of asbestos textiles.(29) HAZARD RUNAWAYS-A TREND? Although the above illustration reinforces the fears that better U.S. protection may result in runaway industry, the underlying question is: how pervasive is the shift of hazardous production? If a trend can be established, is U.S. regulation the decisive causal factor and is it any greater than the general shift in U.S. manufacturing as a whole? All of this is very difficult to assess. The complications become clear when we look at the asbestos industry. Many obstacles stand in the way of making a forceful argument that U.S. regulations will cause runaways, one being that regulations have only been in effect since the early 1970’s. If health hazardous industries are being shifted abroad to avoid compliance, a trend would barely have had a chance to surface in the available data. Specific to asbestos, as we explained in the previous article, there are great differences in the various sectors of the industry, including the fact that compliance with OSHA regulations is easier in some sectors than in others. Furthermore, those differences mean that the possibilities for capital flight vary significantly and regulation is certainly not the only determining factor. TEXTILES CROSS THE BORDER Taking asbestos textiles as an example, one characteristic of textiles is that plants are fairly easy to relocate and another is that the products are relatively easy to transport. Hence, asbestos textiles are likely candidates for escaping U.S. regulations by running abroad. Import/export figures indicate this to be the case. Prior to 1972, asbestos textiles were traded primarily between industrialized nations and the United States exported more than it imported. By 1977, U.S. imports widely outpaced exports and, even more significantly, over half originated in the third world, compared to absolutely none in 1968.(29a A NIOSH study states: Foreign facilities, which may be owned by domestic companies, typically have a competitive advantage over domestic producers since they do not have to pay for environmental controls capable of meeting the OSHA standards.(30) According to one industry study, foreign production now supplies 30-40% of domestic demand.(31) The extent to which the shift of asbestos textile production abroad has been caused by the imposition of occupational health regulations is not, however, entirely clear. In the same decade, there were sharp jumps in all textile imports, not just asbestos.(32) The laborintensive nature of textile production makes the low wages abroad very attractive. Hence, regulation is just one of a number of factors that encourage runaways. Furthermore, during this same period, asbestos textile exports to Mexico grew spectacularly as well.(33) Since the categories for imports and exports are not itemized, it is difficult to explain why both imports and exports have risen, but it is possible that some of the dirtier aspects of asbestos textile production are being exported abroad, and the finished product reimported. One OSHA official accused Raybestos-Manhattan of precisely this activity.(34) Last year the firm completed construction of a new yarn producing facility at its plant in Venezuela. While the company claims that the purpose is to participate in the Andean Common Market, U.S. textile imports from Venezuela, which began in 1972, increased sevenfold between 1976 and 1977.(35) FRICTION PRODUCTS CLOSE BEHIND The production of asbestos friction products may share some of the same motives for moving abroad. At least four U.S. friction material producers are known to have established Latin American subsidiaries. But again, it appears that occupational safety regulations may have had only a minor role in encouraging the shift of production overseas. Low wages abroad for this labor-intensive work, and low transport costs must also be taken into account. It is not unreasonable to expect that some friction products currently being manufactured in the United States for both domestic and foreign markets will be produced abroad in the future. Yet customs reports that lump asbestos friction products together with other materials make it impossible to determine any geographic shifts in production on the basis of import-export data. THE CEMENT STORY Asbestos cement production presents new complications. The market for these products is shifting to countries that are rapidly expanding basic industrial production. Asbestos cement is an appropriate building material for these countries because most of them have already developed indigenous cement industries and the additional technology needed to include asbestos is relatively easy and cheap to adopt.(36) A 1974 geographic breakdown of world asbestos cement output showed South America to be the largest producer, with 35% of the total. Brazil, Mexico and Colombia are the major producers. Within the last decade new plants have opened in Colombia, Guatemala and Jamaica. All in all, production of asbestos cement seems to be shifting abroad, but for a different set of reasons than textiles or friction products. And U.S. companies want a piece of the action. Certain-Teed, the second largest U.S. pipe producer, acquired 49% of Productos Mexalit-the leading a-c manufacturer in Mexico, and announced’its intention to continue expansion in the Western Hemisphere.(38) Such public pronouncements are rare. U.S. companies are not legally required to give out certain types of information considered proprietary for “competitive” reasons. Thus, for example, business compendiums note that J-M, the largest asbestos cement pipe manufacturer, expanded its holdings in Mexico and Brazil, but they do not disclose what is produced, whether for domestic consumption or export, how many workers, or even how large a share they hold. There are indications that U.S. and European transnational corporations own more of foreign production than can be documented without information from the industry itself. The foreign sources are no more helpful. For example, once investigators uncovered the Amatex plant in Agua Prieta, the Mexican government denied to a member of PAHO that any asbestos plant existed in Ciudad Juarez.(39) It was only later that the second Amatex plant was discovered there. Due to the industry/government monopoly on information, it is difficult to prove capital flight for any motive. Even if the increased asbestos production in Latin America was made up entirely of domestic capital, our point is still valid: this production is increasingly satisfying their needs and in some products competing with U.S. production for the U.S. market. Lack of regulation undoubtedly contributes to lower production costs and therefore more competitive prices of foreign goods. The U.S. Dept. of Labor is voicing some concern over the prospect of U.S. job loss due to competitive foreign production. Secretary of Labor Ray Marshall is reportedly developing a plan involving trade discrimination against goods of hazardous manufacture. The idea is that tariffs and quotas would jack up the price of foreign goods produced under working conditions deemed “deficient.” Ostensibly, under such pressure either conditions in foreign plants would improve, or the imports would be priced out of the U.S. market. The business press has been quick to react to this proposal, charging that “it would open the way to arbitrary interference and to rampant protectionism. “(40) The U.S. government’s operations don’t exactly set a shining example of enforcing U.S. standards overseas-none of the occupational safety and health or environmental regulations affect any of the international activities of federal agencies, including the Departments of Defense, Commerce, State, Treasury or the Ex/Im Bank. This means, for example, that U.S. overseas nuclear installations or AID pesticide use are not presently regulated. Recently reform legislation has been drafted to require detailed environmental impact studies before any U.S. government overseas operation is begun. This cautious proposal does not require that the least dangerous alternative is selected, but has nevertheless caused alarm in all the affected agencies. Spearheading the attack, State Dept. officials have charged that the international application of regulations would be an “unwarranted intrusion” in matters subject to the “sovereign authority of other governments.”(41) Apparently, pollution and extremely hazardous work are not considered “unwarranted intrusions.” These “intrusions” mean that foreign workers are increasingly exposed to toxic substances. As it now stands, the tragedy of occupational disease will be writ large in Latin America. The knowledge of past tragedies in the United States has done little to prevent future ones elsewhere. The differences between the social realities of Latin America and the U.S. are used by capital to divide workers from one another. But their struggles for safe work and a clean environment are interconnected. As long as worse conditions exist elsewhere, they will act to depress conditions in the U.S. All the options of the industry, including the threat or actuality of shifting production abroad, affect the situation of U.S. workers. To this we will now turn our attention. ______________________________________________ Tour of a Mexican Asbestos Plant In December 1977, NACLA toured a plant of Techo Eterno Eureka, S.A., which boasts of being the first asbestos cement factory in all of Latin America. As one of three major Mexican producers, the company manufactures pipes, tubing, industrial roofing and water tanks. Eureka’s four plants employ 1,100 production workers who average a take home pay of six dollars a day. The Mexico City plant is located right on a highway bordering the downtown section of the city. It is not a very good advertisement for the construction material it markets. There are gaps between the roof and walls and many windows are broken. An a plant administrator remarked, “The conditions are not exactly optimal”-not for the workers and not for those living in the surrounding homes. As industrial engineer was quick to assure us that in general they “provide minimum but sufficient protection for workers.” He added that because of the very simple production procedures, “it is easier to have an accident in the street than in the plant.” As for job-related disease, plant officials maintained: The problem is not a serious one in production using asbestos fiber as an additive. Of course, workers who have been here for 40 years will suffer from a certain degree of Latin America’s first asbestos cement plant is in the heart of a residential district. pulmonary malfunction. But that’s the same as breathing smog for 40 vears in Mexico City … While we have had cases of partial’ pulmonary incapacitation, no one has been able to prove it has been caused by asbestos. The Mexican Institute of Social Security (IMSS), which classifies businesses in five categories according to how dangerous their production is, sees things somewhat differently. The fabrication of asbestos cement products is listed in their “most dangerous” category. This knowledge has had little apparent effect on the plant we visited. Even though some procedures in the plant are less hazardous than others, because no section is blocked off from another the dust has dangerously spread everywhere. It is accumulated in corners and hangs down from the pipes. We saw men sweep up armfuls of raw asbestos, manually packing boxes of fiber to be weighed. None of these workers wore any type of protective clothing. Elsewhere, rather randomly, some workers wore masks, but everywhere dust could be seen clinging to their wool caps or powdering their boots. No lockers are provided to store street clothes and since workers go home for lunch, twice a day they are unconsciously contaminating their families as well. Contrast this to the warning of an occupational safety and health expert: “There shouldn’t be asbestos that can be touched. When there’s visible asbestos. in clothes and hair, it’s obvious that asbestos is out of control.” In general, the hazardous conditions at Eureka parallel those which led to the closure of the Tyler plant in Texas. Defensively, the engineer remarked as we were leaving, “We produce water tanks that hold the water supply for the homes of Mexico City. We don’t produce cancer.” Yet, as much as they want to deny it, their refusal to acknowledge the dangers of asbestos, the government’s inability to regulate them, and the workers’ innocence of the effects, make it a certainty that at least half of the workers there will die because no adequate precautions are being taken to prevent it. _____________________________________________ REFERENCES III. INTERNATIONAL HAZARDS: 1. H.B. Moreno, Senior Operating Vice-President of Johns-Manville, excerpt from testimony at Congressional Hearings on Asbestos Standard (March 16, 1972). 2. Ray Elling, “Industrialization and Occupational Health in Underdeveloped Countries,” International Journal of Health Services, Vol. 7, No. 2 (1977), p.218. 3. NACLA interview with Dr. Joseph Wagoner, Head of Carcinogens, OSHA (December. 1977). 4. Dr. Roberto Belmar et. at, The Health of Latin America: A Case Study in the Impact of Dependency Upon the Health of Nations. (Unpublished Manuscript, 1977), p. 1 . 7. NACLA interview with Dr. Jorge Fernandes Osorio, head of occupational medicine at the Universidad Autonoma Nacional de Mexico, Mexico City (December, 1977). 8. NACLA interview with Dr. Federico Ortiz Quesada, former head of occupational medicine during the Echevarria Administration, currently working with the Mexican Institute of Social Security. (December, 1977). 9. Sylvia Bermann and Jose Carlos Escudero, “Health in Argentina under the Military Junta.” unpublished manuscript from the Health Studies Group of the Solidarity Committee with the Argentinian People, Mexico City, 1977. 10. Lecture by Dr. Jose Escudero. former public health official in Argentina, Montefiore Hospital, Bronx, New York (1977). 11. Dr. Giorgio Solimano, “Health and Human Rights in Chile,” (Unpublished Manuscript, September 27, 1977). 12. Vicente Navarro, Medicine Under Capitalism (New York: Prodist, 1976), p. 2 2 . 13. Dr. Osorio, op.cit. 14. International Labor Organization (ILO), Organization of Occupational Health Services in Developing Nations (Geneva, 1976), pp.5,75 and following. 15. See NACLA Reports: “Harvest of Anger: Agribusiness and Farmworkers in Mexico’s Northwest,” (July-August 1976) and “Del Monte: Global Agribusiness,” (September, 1976). 18. New York Times, January 24, 1978. 19. Barry Commoner, The Closing Circle (New York: Alfred A. Knopf, 1971), p.76. 20. NACLA interview with Blanca Raquel Ordonez de la Moda, head of the Sub-Secretariat of Environmental Improvement, Mexico City (December, 1977). 22. Barry Castleman, The Export of Hazardous Factories to Developing Nations, soon to be published manuscript, October, 1977. NACLA wishes to thank Barry Castleman for his extensive research on the subject and generous help. 23. Ibid., p.10. 24. Dr. William Johnson, formerly of NIOSH, and Gail Yoakum, reporter for the Arizona Daily Star, March 27 and May 30, 1977. 25. See NACLA Report: “Hit & Run: U.S. Runaway Shops on the Mexican Border,” (July-August, 1975). 26. Byron Harris, “The Treacherous Bargain”-news special for WFAA, local Dallas television, September, 1977. 27. NACLA correspondence with Dr. Boris Velimirovic, Chief Field Officer, U.S.-Mexico Border, PAHOE, regional office of the World Health Organization (October,1977). 28. Confidential financial source. 29. Barry Castleman, op.cit., p.8. 29a. Bureau of Census, FT246 U.S. Imports for Consumption, TSUSA Commodity by Country, Department of Commerce Cumulative Report 1967-1976. 30. Castleman, op.cit., p.4. 31. Weston, op.cit., pp.4-90. 32. ILO, General Report: Recent Events and Developments in the Textile Industry, Textile Committee, Ninth Session, Geneva, 1973. 33. Bureau of Census, FT410 U.S. Exports Schedule B,Commodity by Country, Department of Commerce Cumulative Report 1967-1976. 34. NACLA interview with Dr. Joseph Wagoner, op.cit. 35. TSUSA year-end figures, 1976 and 1977, op.cit. 36. United Nations Industrial Development Organization, Fibro-Cement Composites: Report and Proceedings of Expert Working Group Meeting Vienna,-October 2024, 1969 (New York: United Nations, 1970). 38. Asbestos magazine, December, 1974 and August, 1974, p.17. 39. Byron Harris, op.cit., Part I. 40. Barron’s, January 16, 1978. 41. New York Times, January 19, 1978.
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