WARNING: This site deals only with the corporate corruption of science, and makes no inference about the motives or activities of individuals involved.
    There are many reasons why individuals become embroiled in corporate corruption activities - from political zealotry to over-enthusiastic activism; from gullibility to greed.
    Please read the OVERVIEW carefully, and make up your own mind.

OPINION ONLY

If you don't know who George Carlo is, read at least Part 2 of this omnibus time-line first. This section is in the form of a biography of one of the most flexible science-for-sale entrepreneurs of our time.

In the period 1993 to 1995, while supposedly working full-time directing cellphone health research for the Cellular Telephone Industry Association (CTIA) he also continued to assist the tobacco and chemical industries and developed new interests in working for Dow Corning on their Breast Implant rupture problem, and with a Dow Chemicals pharmacuetical subsidiary on Immunex, supposedly a potential cure for AIDS.

It is important to realise that not all of this research work is dubious. The Breast Implant Public Health Project, while funded by Dow Corning and/or Dow Chemicals, appears to have served a useful purpose — although it leaves you wondering why it required Carlo to register a Delaware-registered corporation, and why he used an address at George Washington University. It was actually run by Carlo's staff out of the same offices which conducted the cellphone-health research.

Like many of these health scares, there's a reasnable median position between the outright denials and conspiratorial coalitions and science-corruption of the corporations which are focused on protecting their profits, and the often-shrill, usually-exaggerated doomsday claims of the activists.

Science-for-sale entrepreneurs like George Carlo, Ernest Wynder, Steve Milloy and the dollar-a-word journalists like Michael Fumento tend to occupy this space, and are paid to provide the more subtle spin necessary to generate political opposition to more restrictive regulations. In the process they destroy public trust in general science.

This is a continuation of Part 2, and it runs roughly parallel with the Wireless Technology Research (WTR) project dealt with in Parts 3 and 5.

Some key documents

1993 Sept: The Nufarm dioxin spill: The Australian Journal of Public Health publishes Carlo's reply to criticism of his Melbourne Water Supply report.

Noel Turnbull a Hill & Knowlton employee, later attacked Greenpeace for exposing the Nufarm spill in a text book on Australian public relations::

In the 1980s Greenpeace conducted one of its raids on a western suburban plant owned by Nufarm, an agricultural chemical manufacturer. They accused the plant of being a source of toxic threats to the water supply.
[Note "accused" — by then it had been established beyond doubt.]

    In this case Melbourne Water, the local water utility, demolished Greenpeace's arguments with an aggressive campaign based on scientific evidence obtained from their own records and from independent experts.
[This refers to both George Carlo and Michael Gough]

    Admittedly it was one of the few examples where scientific evidence triumphed over pressure group activism, but it was also an example of how determined opponents can be neutralised.

1994: thru 1988: Carlo is still on the selected committee of the Office of Technology Assessment (OTA), Agent Orange Advisory Panel which deals with dioxin contamination of Vietnam war veterans. This was run by Michael Gough who had helped him out in Melbourne over the NuFarm dioxin spill.

Claims made in George Carlo's 1988 C/V

1994 /E: Pharma Pacific Management At some time in the 1994-95 period Carlo appeared in the literature as the Technical Director for two associated drug companies nominally based in Sydney, Australia. They also had offices in the USA at Florida and Washington (at his office addresses).

    These associated companies were Pharma Pacific, which seems to manufacture and distribute immune-suppression drugs and vaccines, and Pharma Pacific Management Pty. Ltd, which is the holding company. They also appear to be involved in government lobbying on behalf of a wider group of vaccine-producing companies in Australia.
[It later emerged that they were secret phramacuetical subsidiaries of Dow Chemicals.

    When approached by Australian journalist Stewart Fist, Pharma Pacific was keen to offer the services of George Carlo as a keynote speaker at a conference in Australia.]

1994: The corporate contributions to the 'public relations & research' budget of Chlorine Chemistry Council (CCC) was $12 million, up from $2 million in 1992.

    The CCC was the latest name change for the Chlorine Institute (CI) , which was a CMA lobbying organisation which had hired Carlo as a consultant and planted him on the Banbury Conference. The organization mainly consisted of synthetic-organic chemical manufacturers and their allies from the American Forest and Paper Association (AFPA).

    The Synthetic Organic Chemical Manfacturers Association (SOCMA) was run by Paul E Oreffice, President of Dow Chemicals, and William H Bricker, President of Diamond Shamrock Corp.

1994 Jan: (Winter) Hazardous Waste and Hazardous Materials, mentions that George Carlo was Chairman of an Advisory Board for an organization called the "Cement Kiln Recycling Association". [See Google listing]

    One article by Dr Gerson Smoger, the lawyer for a large number of Times Beach dioxin victims, says that...

George Carlo is a close friend of the chemical industry, was also influential in the "Cement Kiln Recycling Association" [and an advisor on] hazardous waste incineration in cement kilns — and a consultant of the "Chlorine Institute".

[in German] See latest information on dioxins:

1994 Feb: The National Journal (Dec 3 1994) gives the history of the Dioxin Wars.

Dioxin is a by-product of some chlorine manufacturing processes, and companies that make or use chlorine products could face new restrictions if EPA proceeds with the regulations.

    Even before the report's release, the Chlorine Chemistry Council, a unit of the Chemical Manufacturers Association (CMA) that includes such firms as Dow Chemical Co. and Occidental Chemical Co., launched a PR campaign to defuse its expected conclusions. In February, the council hired Ketchum Public Relations, which started rounding up scientists sympathethic to the industry's point of view.

    "We identified a number of independent scientists and took them on the road" to meet with journalists, academics, political leaders and local health officials, Mark Schannon, an associate director of Ketchum's Washington office, said.

    The blitz, which started in May and covered at least 30 cities, was designed to undercut the press coverage that the EPA report was expected to receive when it was released in September [Which confirmed that dioxin was a probable human carcinongen]. "Basically what we're trying to do is assure that industry's voice is heard by people who make policy decisions both here and around the country," Schannon said.

    The CMA is also providing about $200,000 to finance a scientific review panel to provide comments to EPA about the quality of its dioxin reassessment. The panel is co-chaired by John A. Moore, an EPA acting deputy administrator during the Reagan Administration who is now the president of the Institute for Evaluating Health Risks, a Washington think tank.

1994 Mar: /E Carlo's associate, John D Graham of Harvard Center for Risk Assessment was enlisted as a member of the Environmental Protection Agency's first Science Advisory Board on the risk assessment on dioxin.

See Graham biography:

• 1994: EPA releases a draft Health Assessment Document for 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds. The draft assessment concludes that these chemicals may be harmful at levels similar to those found in the general public, increasing the risk of cancer and causing potential damage to the immune, nervous and reproductive systems (EPA 1994).
• 1995: EPA's Science Advisory Board completes its third review of EPA's dioxin assessment and agrees with the agency that "the margin of safety (between background exposures and levels of exposure where effects have been observed in test animals) for dioxin-like compounds is smaller than the EPA usually sees for many other compounds" (SAB 1995).
• 1997: The International Agency for Research on Cancer declares dioxin a known human carcinogen (IARC 1997).

1994 Mar 15: GEP: Matt Winokur of Philip Morris International has emailed his European team about the possibility of the tobacco industry floating their own standard for "Good Epidemiological Practices (GEP)".

    GEP became a Philip Morris project to restrict the scope of environmental and health regulators to use meta-analysis and some other evidence-accumulating statistical techniques. Until this time the design of the GEP standard had been largely controlled through the Chemical Manufacturer's Association (CMA) for their own advantage. Philip Morris saw it as a way of countering the work of the World Health Organisations passive-smoking research program, being conducted by their research arm, the International Agency for Research on Cancer (IARC).

    Winokur emailed Tom Borelli asking:

I need the evaluation:of the CMA's GEP criteria, and any further comments SA/S&T may have, prior to our next IARC task force meeting on March 29. Will you be able to have the consultant's evaluation by then?

From: Thomas Borellii
Subject: GEP review
I reviewed the criteria. It's not a bad place to start by [but] it lacks teeth and as written it does not have enough meat to help us on ETS.

    However setting up our own standards is a good project for us and our consultant's program. It would be good offensive strategy for our consultant's to be out there trying to fix epidemiology instead of being critical all the time.

I will send you a copy of the Carlo survey on epi[demiological] standards as a possible starting point.

• Julian Peto suggest, in a 1992 IARC journal, that relative risks for "passive smoking" under 1.3 may be "beyond the the limits of reliable epidemiological inference."
• George Carlo's 1992 study examining research standards and communications strategies related to human health risks.
• Douglas Altman's letter to the editor of the BMJ. January 29 1994, in which he concludes that "we need less research, better research, and research done for the right reasons."

I'd appreciate your comments before our next Task Force meeting on March 29. Thesc studies may be particularly appropriate given the preliminary evaluations of the GEP to the effect they are not specific enough to discredit poor ETS science.

1994 Mar 17: GEP: Helmut Reif of Science & Technology (S&T) in Switzerland adds his own comments while circulating the Borelli/Winokur suggestions.

I think that this covers our opinion aa well, The GEP Is not bad, but too soft. However, it goes into the right direction and could serve ae a piece of "constructive critique" of the existing approaches for our consutants.

1994 Mar 18: GEP: Helmut Reif has written back to Matt Winokur. He is enthusiastic about GEP.

In response to your March 15th note on Epidemiology standards, I am most heartened to see the interest you are taking in getting your feet wet. It will be most helpful in the future.

    On the specific points, let me comment as follows:

• Richard Peto (Peto was useful here because he was a student and collaborator of Richard Doll and therefore anti-tobacco.)
• Douglas Altman paper. (Altman was a critic of statistics and especially meta-analysis as used by the EPA)
• George Carlo's papers

  I had already seen this paper, and here too, though it appears helpful, a double standard is often applied to tobacco. However, encouragement of this type of thinking can only be helpful in the future, perhaps via the GEP work.

1994 March 25: TASSC: APCO memo to PM's Matt Winokur "Thoughts on TASSC Europe"

    This was also the formal beginning of the Euro-TASSC project — to create a similar operation in Europe to that now being run by Steve Milloy in the USA. APCO wrote:

Specifically, wc recommend that a European TASSC be formulated to do the following:
• Preempt unilateral action against industry.
• Associate anti-industry "scientific" studies with broader questions about government research and regulations.
• Link the tobacco issue wilh other more "politically correct" products.
• Have non-industry messengers provide reasons for legislators, business executives and media to view policies drawn from unreliable scientific studies with extreme caution.

Already, there are several opportunities to establish TASSC in Europe. We have had extensive conversations wilh our Grey/GCl network in Europe, which encompasses offices in 33 cities and 19 countries. They also are confident that scientists and businesses can be attracted to the group if it is positioned in a credible manner.

In each of these issues, there has been considerable discussion as to whether sound science is being used as a basis for these decisions. The diversity of these issues, and their tremendous impact upon business and industry, provides an excellent "tie-in" to the work TASSC is currently undertaking in the United States.

    TASSC currently has approximately 75 key scientists who arc part of our scientific and academic support team. In a preliminary review of their backgrounds and expertise, we have identified at least 20 to 25 with experience in international work. This involvement often includes affiliations with international groups — a natural entre for TASSC recruitment.

[Don't imagine that all of these 75 were financially corrupted by the tobacco industry. Politically-partisan scientists in the USA are notoriously gullible and easy to con when asked to support such motherhood issues as market-based "sound science" against government-imposed "junk-science."]

• Use a TASSC conference in June to attract key European scientists to the idea of starting a similar group in Europe.
• Identify signatories of the Heidelberg Appeal who already are TASSC members to explore the possibility of starting a European TASSC
• Put together concept papers about a European TASSC to use with potential business contributors.
• Initiate some meetings with possible contributors who might be APCO, Grey, GCI or Burson clients.

APCO's thoughts on TASSC Europe:

1994 May 31: Hockaday also followed up, advising Matt Winokur at Philip Morris that APCO has just received a copy of Carlo's 'Bias Study/Health Scientists Survey' and could see the potential for using these to promoting the TASSC idea in Europe.

Thank you for sending a copy of the survey on epidemiology. We agree that the results could be a good basis for a European scientist meeting. We will follow-up with Tom Borelli to discuss the survey in more detail.

    For your information — Dr George Carlo, Chairman of Health and Evironmental Sciences Group, Ltd., who coordinated the survey, is a member of the TASSC Science Advisory Group. Tom [Hockaday] met with Dr Carlo recently, and he has indicated a willingness to play an active note in the coalition.
[Remember that this coalition also involved the Federal Focus Inc operation that produced the "London Principles" and later "GEP" — run by Carlo's friends/partners Thorne Auchter and Jim Tozzi.]

    We havc provided Chuck Lister [PM's London lawyer with Covington & Burling] a list of the European scientists recommended by TASSC members as potential participants in a European meeting
[This could have been the proposed "sound-science/junk-science" meeting to create a "Euro-TASSC" or it may have been connected with GEP... or both.].

He has forwarded us information and an initial assessment of the list and will be providing further thoughts on these suggestions.

    We are working on the proposal for the European scientist meeting and should have a document for your review shortly.

1994 June 15: TASSC & GEP: Tom Hockaday of APCO writes to Winokur on the Euroscience/Euro-TASSC project:

Enclosed is a preliminary working draft of a list of "Guiding Scientific Principles" for your review. These are the principles we have discussed in the past that have the aim of providing a concrete document to challenge cxamples of unsound science in public policy decisions.

Tobacco, Lawyers and Public Health
Researchers EK Ong and Stanford Glantz at UCSF have produced good overviews of this Euro-TASSC project and also of GEP. See

---

The Nufarm dioxin spill: Re Melbourne Water Supply: In June 1994 the Victorian State EPA listed a dioxin clean-up site at Werribee:

Owner/Occupier: Nufarm Limited
Contaminants: Chlorophenols, pesticides, dioxin, phenolic compounds
Comments: Monitoring of soils at the site has shown some contamination by chlorophenol and dioxin. Nufarm is investigating the treatment of contaminated soils on site by means of bioremediation. Trials are underway.

1994 June 22: Margery Kraus, the nominal head of APCO Associates, has written to a group of PM misinformation executives summarising the recent discussion they've had about the "Euroscience" project [Euro-TASSC, later ESEF]

    By now, TASSC had managed to sign up a few hundred legitimate scientists simply on the basis of a motherhood proposition that "governments should only regulate on the basis of sound science rather than junk science."

[The career and vacation possibilities of membership in such an organization should not be discounted. It may also have occurred to some of these scientists that industry-funded, all-paid, skeptical science conferences were usually held in Florida or the Caribbean during winter.].

    Both APCO and Burson-Marsteller were competing for PM funding to create this parallel organisation in Europe, and when the battle began to get out of hand, Philip Morris shared the work and rewards. Margey Kraus outlines the new arrangement between the companies.

1. We agreed that we would work together to organize a small (20-30 people) meeting of leading American and European scientists on the issue of sound science and public policy, with special emphasis on GEP. These expert seientisrs would be especially concerned about and knowledgeable about epidemiology. The conference will be in Europe in early fall.
2. APCO/Burson would work together to identify both the appropriate organizations to to convene/sponsor the working group and the scientists.
3. The focus of the meeting will be to review and hopefully endorse sound principles of epidemiology, as well as to identify opportunities to proactively support these principles.
4. The client will work with the consultants to determine if the sole focus of the first meeting is GEP or whether it should extend to other areas of potential abuse, such as low-level risk, risk analysis and/or more general principles like those identified by the scientists in various US groups, including TASSC.

1994 Aug 14: Charles Lister of the London office of Covington & Burling has written to Philip Morris outlining their work recruiting scientists for a London seminar on Good Epidemiological Practices (GEP). They are winnowing out known anti-smoking scientists.

    They have also faxed to Philip Morris's GEP-project team, a list of scientists [Category B2] from various European countries who were to be considered as candidates for the London Principles/GEP conference.

[B2 refers to "epidemiologist reasonably balanced on tobacco issues - not from institutions, known to be extremely hostile to tobacco."
B3 refers to "influential epidemiologists known to have strongly anti-tobacco views".

Only two on the B2 list are clearly tobacco industry lackeys — and none were included in the final panel of the London Conference. Howeve, oddly, at least one on the B3 list was a known consultant to the industry.]

    The list has been circulated within the GEP team, along with the proposed Criteria for Epidemiology, and a set of Guidelines, prepared by the lawyers.

[They are following the age-old principle of always writings the conclusions, before you hold the conference!]

C&B memo PM's internal Email
List B2 List B3
Criteria Covington & Burlin's guidelines doc.

1994 Aug 16: /E The EPA was planning to release its determination of the dangers of dioxins in September. Mark Schannon, associate director of Ketchum Public Relations in Washington was recruiting...

scientists sympathethic to the industry's point of view [on the safety of dioxins].

    "We identified a number of independent scientists and took them on the road" to meet with journalists, academics, political leaders and local health officials, Mark Schannon, an associate director of Ketchum's Washington office, said.

    The blitz, which started in May and covered at least 30 cities, was designed to undercut the press coverage that the EPA report was expected to receive when it was released in September.

Dioxin knowledge in September 1994

Behind the Scene — a later history of dioxin article Aug 31 2001. In September 1994, the EPA dioxin reassessment final draft was released re-affirming that dioxins can cause cancer.     As expected, the industry scientists rejected several chapters in the draft document, forcing the agency to rewrite them, thereby delaying the process of finalizing the report. After a six-year delay, finally, in June 2000, the EPA released a revision of the 1994 reassessment report. And EPA found even stronger links between exposure to dioxin and adverse impacts on human health

1994 Sep 14: James Baller, Carlo's lawyer friend and co-author, provided a statement to a Senate Committee on Finance hearing on the Superfund Reform Act of 1994 (which was an attempt to modify the requirements for clean up of toxic dump-sites). Their joint paper is titled "Abolishing ATSDR'S Role at Superfund Sites would be a Serious Mistake."

    The Agency for Toxic Substances and Disease Registry (ATSDR) had been 'captured' by the chemical industry and come under heavy criticism for inaction, and a number of activist groups were promoting to Congress that control of the Superfund program should revert entirely to the EPA.

    Baller presented comments which had been prepared by himself, with George Carlo and Kelly Sund (Carlo's secretary/general factotum at HES). They were opposed to the EPA taking control of cleanup measures, and especially of the EPA replacing the ADSDR completely.

We focus our comments on the portion of S.1834 that would transfer to the Environmental Protection Agency (EPA) the authority that the ATSDR now has to conduct health assessments and related activities at Superfund sites.

    This action was apparently intended to respond to claims by certain community activists that ATSDR has not been responsive enough to the concerns of communities living near Superfund sites.

    These comments are based upon the many years of experience that Dr George L. Carlo, Kelly Sund and I have had with public health issues and ATSDR Dr Carlo, in fact, was one of the principal draftsmen of the language in the Superfund Amendments and Reauthorization Act of 1986 through which Congress expanded and spelled out ATSDR's responsibilities in detail. [Carlo's involvement here had been primarily as a contractor to the Chemical Manufacturer's Association.]

Conclusion:
Our national cannot afford to squander its limited resources on remedies that are unnecessary or protective beyond a reasonable margin of safety.

[E]ven if ATSDR's reputation with community groups were truly beyond repair, it would be a serious mistake to give EPA exclusive authority over the health assessment process.

The views expressed in these comments are our own and do not necessarily reflect those of all of our clients.

1994 Sept 19: J Madelaine Nash article in Time magazine: "Keeping Cool About Risk" quotes John Graham of the Harvard Center for Risk Analysis (a later partner in Carlo's EMF work) as saying

"Phantom risks and real risks compete not only for our resources but also for our attention... It's a shame when a mother worries about toxic chemicals, and yet her kids are running around unvaccinated and without bicycle helmets."

1994 Oct 13: Two groups associated with Carlo have joined forces in a Philip Morris project.

    Federal Focus (Thorne Auchter/Jim Tozzi) and John D Graham's Harvard Center for Risk Analysis have set up the Lansdown conference The proper role of epidemiology in regulatory risk assessment which was funded secretly by Philip Morris. This is the prelude to the London Conference which the same group ran the following year. It is loaded with the tobacco industry's scientific contractors.

[Goran Pershagen appears to be the lone anti-smoking/non-tobacco lackey participant.]

Agenda I Agenda II List of participants

1994 Nov: Newt Gingrich and the Contract with America mid-term election win for Republicans.

1994 Nov 11: The organisation of the London Conference to promote Good Epidemiological Practices (GEP) is now well advanced. Dr Franz Adlkofer, the head of the German Verband (VDC) has been organising in Europe, and they are anxious to persuade Ernst Wynder to recruit Julian Peto (anti-smoking epidemiologist) as a celebrity, without telling him that the tobacco industry is involved. [This report by PM's Helmut Reif is in Germanic English]

Adlkofer. had made contacts to Prof. Hofmeister, BGA, and asked him to contact Richard Peto, Prof. Moishe Skoll (Skloe ?), Baltimore (editor of Am. J. Epidem.), and Wynder (the latter two obviously being in favor of the project).
[Wynder was helping organise the London Conference.]

    At no level, the ETS-relevant questions will be involved, only the general question of having some guidelines for low level epidemiology will be discussed.
[They are not to be told this is a tobacco industry operation]

    The conference should be organized in 5/95. Wynder will contact the mentioned persons [Julian Peto and Skoll] and will ask for NCI funding, as Hofmeister will try to get EU funding.
[The tobacco industry managed to get a lot of government funding for their projects, by just concealing their own involvement]

    Adlkofer & Hofmeister will visit Wynder in 1/95 in NY after Hofmeister has made his final decision (principally in favor but some hesitations to come into contact [become involved] with the industry).

1994 Dec 3: An article in The National Journal "Back Off!" on the arrival of "Contract with America" with its associated Republican-controlled House — and the consequent expansion of the US lobbying industry, records that:

business lobbyists are fighting back. And the battle may intensify as Republicans take control of Capitol Hill.

    In September, EPA issued a report confirming that dioxin was a probable human carcinogen and raising worries about other effects of dioxin, including possible reproductive system problems.

    Even before the report's release, the Chlorine Chemistry Council, a unit of the Chemical Manufacturers Association (CMA) that includes such firms as Dow Chemical Co. and Occidental Chemical Co., launched a PR campaign to defuse its expected conclusions. In February, the council hired Ketchum Public Relations, [ which started rounding up scientists sympathethic to the industry's point of view.

    "We identified a number of independent scientists and took them on the road" to meet with journalists, academics, political leaders and local health officials, Mark Schannon, an associate director of Ketchum's Washington office, said.

    The blitz, which started in May and covered at least 30 cities, was designed to undercut the press coverage that the EPA report was expected to receive when it was released in September. "Basically what we're trying to do is assure that industry's voice is heard by people who make policy decisions both here and around the country," Schannon said.

    The CMA is also providing about $200,000 to finance a scientific review panel to provide comments to EPA about the quality of its dioxin reassessment. The panel is co-chaired by John A. Moore, an EPA acting deputy administrator during the Reagan Administration who is now the president of the Institute for Evaluating Health Risks, a Washington think tank.

    Another group that has been pressing for stricter risk assessment policies is the Coalition for Uniform Risk Evaluation (CURE), which is run by Thorne Auchter, who headed OSHA for a time during the Reagan Administration, and Washington lobbyist Wayne H. Valis of Valis Associates.

    Members of one coalition include the Edison Electric Institute, FMC Corp. and the Grocery Manufacturers of America Inc.(who lobbied for the tobacco industry)

1994 Dec 3: The National Journal reports on the lobbying for regulatory change under Newt Gingrich's Contract with America in the.

1994 Dec 9: Thorne Auchter, as the Director of both Federal Focus and the Institute of Regulatory Policy which claimed to have commissioned Carlo's 'Bias' and 'Health Scientists' studies, writes on Federal Focus Inc letterhead to Philip Morris.

Federal Focus is a non-profit 501(C)(3) organization which performs research and studies dealing in areas of current public policy.

By this letter, we are requesting an unrestricted grant in support of those activities in the amount of $250,000.

1995: Carlo's Bias Study originally been promoted jointly with Maurice LeVois before they split their HES company and went their separate way. Maurice LeVois then joined forces with a new Californian partner, Max Layard, who was also a dedicated tobacco industry science-for-sale lobbyist. They jointly published

Publication bias in the environmental tobacco smoke / coronary heart disease epidemiologic literature.
By LeVois, M.E., and M.W. Layard in Regulatory Toxicol. and Pharmicol. 21, 184-191 (1995).

1995 Jan: /E EuroTASSC and GEP: The list of possible scientists to be invited to Philip Morris's London Conference [on Epidemiological standards] were passed for checking by both Philip Morris Corporate Affairs (Science & Technology Issues) and the tobacco lawyers, Covington & Burling.

    The London Panel conference was held a year after the preliminary (testing the waters) Lansdowne Conference, and included many of the same trusted scientists who are listed as the nominal organizers.

• Note: This is a Confidential DRAFT of a Nov. 1999 thesis by Elisha Ong obtained by Philip Morris — not a tobacco industry document. Philip Morris obviously had someone in the office of Stanton Glanz at the University of San Francisco, who leaked this part-edited draft.
  
• Note also that the only obvious 'odd-man-out in the Lansdowne and London conference lists is anti-smoking activist Goran Pershagen, who was probably too well known and respected in Scandinavia to ignore. He also gave both conferences some credibility.]

• B1 [Not included in this document]
• B2 are "epidemiologist reasonably balanced on tobacco issues - not from institutions, known to be extremely hostile to tobacco."
  [C&B had also checked on the scientist known close collaborators.]
• B3 are "Influential epidemiologists known to have strong anti-tobacco views."
  [Naturally none of this group were selected.]

The "London Panel" of experts on Good Epidemiology Practices convened by Federal Focus, Inc.

• John Ashby, Zeneca Central Toxicology Laboratory, UK
  [Ex Imperial Chemical Industries toxicologist; member of Advisory Committee on BELLE (Biological Effects of Low Level Exposures.) run by the CMA.]
• Dr George Carlo The Carlo Institute, Health and Environmental -Science Group, Ltd., and Professor, The George Washington University, Washington, DC, USA
• Dr Samuel M. Cohen University of Nebraska Medical Center;
  [Saccharin research for ILSI and food processing industry; CTR tobacco grants applicant; appears genuine.]
• John S. Evans, Harvard School of Public Health,
  [Close associate of JD Graham; member/partner the HCRA][Also at Lansdowne]
• John D. GrahamCenter for Risk Analysis, Harvard-School of Public Health, (later head of HCRA)
  [A science-for-sale grifter for any industry with money. Graham and Carlo were also working together at this time for the CTIA on cellphones.] [Also Lansdowne organizer]
• Walter Holland, (retired professor) University of London.
  [Researcher for Imperial, Gallaher and Carreras-Rothmans. Tobacco 'friend' on government panels.]
• Linda C. Koo, University of Hong Kong,
  [Tobacco industry secret 'WhiteCoat' (Her payments were laundered thru Sara Liao); passive-smoking researcher to counter Hirayama; co-researcher with Ragnar Rylander][Also Lansdowne, organiser]
• Genevieve M. Matanoski, Johns Hopkins University/University of Maryland
  [Philip Morris consultant; NHANES passive smoke study; Chairperson EPA Science Advisory Board; HCRA's peer-review panel member for EMF/EPRI review; SAB member for the CIAR; co-investigaor on CIAR grants.] [Also at Lansdowne]
• D. Warner North Decision Focus, Inc. California,
  [Consultant/lobbyist to the CMA, Chevron, Uniroyal, and a variety of other industry groups; member of AIHC (CMA);Panelist on EPA Safe Water Proj 65, embroiled in corruption allegations]
• Dennis J. Paustenbach Chemical Risk Division, McLaren/Hart
  [Another infamous science-for-sale grifter for chemical and tobacco companies; later ran Exponent Inc.] [Also Lansdowne, organiser]
• Goran Pershagen Karolinska Institute/Hospital, Stockholm, Sweden.
  [Anti-tobacco passive smoking researcher; IARC consultant. The tobacco industry had an associate, Dr John Wahren, who fed them information they gleened from Pershagen about IARC studies.] [Also at Lansdowne]
• James J. Schlesselman, University of Pittsburgh
  [Statistical analyst/theorist and a minor guru in statistical theory; critic of 'weak-association' standards/cause-and-effect; CTR grants.]
• Thomas B Starr, ENVIRON Corp.
  [Science-for-sale; participated in McGill ETS Conference; paper/dioxin & tobacco contractor; Chem Ind. Inst of Toxicology (CIIT); HCRA associate of JD Graham.]
• James A Swenberg, University of North Carolina, Chapel Hill.
  [Confidential science consultant on DNA for RJ Reynolds; CIIT; CMA.]
• Mary Jane Teta, University of Massachusetts, Danbury, Connecticut, USA
  [Harvard Center for Risk Analysis; Union Carbide; CMA's GEP panel; contract consultant Exponent Inc.; Paustenbach associate.]
• Erich Wichmann, University of Wuppertal, Oberschleissheim, Germany.
  [East German govt.workplace air-quality expert. Tobacco researcher with links to Philip Morris's secretly-owned INBIFO labs; consultant to WHO's IARC.]
• Gary M Williams, American Health Foundation,
  [Carlo associate in tobacco and EMFs.]
• Ernst L Wynder, American Health Foundation
  [Tobacco researcher/consultant, Carlo associate in tobacco, EMFs, Nocebo.] [Also Lansdowne, organiser]

1995 Jan 3: Carlo's Bias Study forms the foundation of an op-ed by Jerry Taylor of the Cato Institute (also heavily funded by Philip Morris) "Cancer Risks for Thee, but not for Me."

    Taylor reproduces the same "EPA is biased against second-hand smoke" opinions of other well-established tobacco scientists, Bruce Ames, Alvan Feinstein and Ragnar Rylander. He also favourably quotes James Le Fanu of London's Sunday Telegraph (another well-known tobacco-friendly journalist) who worked for Rupert Murdoch (who was a director of both Philip Morris and Cato).

See Philip Morris's preview draft copy from Taylor
The copy actually published

1995 Feb 22-23: AIDS: The National Institutes of Health (NIH) run a two-day meeting of the National Advisory Allergy and Infectious Diseases Council (NAAIDC) in Bethesda which was open to the public. It was to discuss policy about diseases lik Lymes Disease and AIDS, and review grant applications.

    The minutes list 41 members, 165-odd staff; and 41 observers. Among the observer group labeled "Others:" are three names stand out:

• Dr George Carlo, Pharma Pacific/HES Group
• Ms Kelly Sund, Pharma Pacific/HES Group
• Ms Hollie Vaughan, Pharma Pacific/HES Group

1995 Mar 13: AIDS: An AEGIS report in the Chicago Tribune (14 March) and USA Today (15 March) "Miracle Cure for AIDS" reveals that Louis Farrakhan [of the Nations of Islam] and George Carlo (working for Pharma Pacific) were slugging it out over who had US rights to sell the anti-AIDS drug Immunex. {Farrakhan had a reputation as a hater of homosexuals!] Carlo says his firm has the tradename and that the drug was not legally available in the US while Farrakhan was associated with a group known as "Abundant Life" which ran some AIDS clinics.

    Carlo was listed in 1995 as the Technical Director for the two associated Phama drug companies nominally based in Sydney, Australia, but also with offices in Florida, and Washington (at his office addresses). He was acting as a front to cover the ownership of these companies by Dow Chemicals.

    Pharma Pacific, [sometimes known as 'Pharma Pacifica'] manufactured and distributed immune suppression drugs and vaccines, and Pharma Pacific Management Pty. Ltd, was perhaps the holding company. It also appears to be involved in government lobbying on behalf of a wider group of companies selling vaccines.

[The later address of Pharma in Australia turned out to be the same as that of NuFarm the maker of RoundUp herbicide. NuFarm was a subsidiary of Fernz, which was itself the New Zealand subsidiary of Dow Chemical.]

1995 Mar 14: AIDS: Chicago Tribune story "Aids Hope of Hoax In A Bottle"

WASHINGTON — In the past two years, the U.S. government has poured $571,521 into a sparsely furnished clinic in a low-income District of Columbia housing complex, where the Nation of Islam's chief doctor sells a "miracle drug" he claims will cure AIDS.

    From his Abundant Life Clinic and nearby mosque, Nation minister Dr Abdul Alim Muhammad dispenses a heady brew of racial diatribes, grandiose promises and illegal medications.

    Alim, as he is called, and his boss, Nation of Islam leader Louis Farrakhan , preach that the AIDS virus was created by the very entity that funds the Abundant Life Clinic — the US government.

    Alim told a 1992 Nation convention in Atlanta that "the present president of the United States, George Bush, played a leading role in developing a policy of genocide against non-white people all over this earth, and we believe that the AIDS virus is a direct consequence of that plotting and planning in secret."

    But Nation of Islam publications claim that Alim has a "miracle drug" for the deadly virus that has spread disproportionately among America's poor and black, a medicine called Low Dose Oral Interferon Alpha, or interferon, that is derived from naturally occurring human immune system cells.

    In the midst of Alim's promotional tour, and during the Nation's 1992 convention in Atlanta, Farrakhan announced that he just "three minutes before" won "the exclusive distribution rights of Immunex (a form of interferon) throughout the United States of America."

    Two days before his announcement, however, the for-profit Per Ankh Inc. had been formed to distribute the drug, District of Columbia corporation records show.
Government agencies warn against interferon as an AIDS treatment because more than a dozen studies have shown it is not effective.
[Alim was Farrakhan's national spokesman, the Nation of Islam's Minister of Health and Human Services and head of the Washington mosque. He was a 45-year-old, non-practicing surgeon once known as Maurice Peters Jr. born in York, Pa.

    Low Dose Interferon was developed by veterinarian Joseph Cummins as a way to bolster cows' immune systems. The rights appear to have been sold to either Carlo himself, or to Pharma Pacific]

    Alim told mosque members that Per Ankh was "your very own pharmaceutical company," and called it "a subsidiary of the Nation of Islam, Incorporated.

"Listing its phone number at the Abundant Life Clinic, the for-profit company run by Alim and [Louis] Farrakhan's son-in-law advertised its pills in the Final Call newspaper: "Urgent urgent urgent," said a November 1992 ad: Interferon is "available for treatment of... full-blown AIDS."

    "How could anyone give them rights to distribute the drug? It's illegal to sell it in the United States," said Dr George Carlo, acting technical director of Pharma Pacific Management Ltd., the Australian company that owns the trademark for Immunex.

    Pharma Pacific never has had any arrangement with the Nation of Islam and wouldn't sell the untested product as an AIDS treatment "even with FDA approval," unless there was proof that it worked, Carlo said.

    Several samples of bootlegged pills obtained by Carlo contained no interferon, probably because the chemicals had broken down, he said.

1995 Mar 15: AIDS: New York Times article Nation of Islam Clinic Markets AIDS 'Cure'

A Nation of Islam clinic in Washington, DC, which has received almost $600,000 in federal funds during the past two years, is dispensing an unlicensed "miracle cure" for AIDS, the Chicago Tribune reported on Tuesday.

    The Abundant Life Clinic is run by Dr Abdul Alim Muhammad, the Nation of Islam's chief doctor, who once accused the federal government of developing HIV to eradicate blacks. Alim describes what he is selling as a form of interferon, which studies have found to be ineffective in fighting AIDS. In Nation of Islam publications, the clinic advertises that Alim has found the cure for HIV. He said, in a 1992 speech, that one of his pills taken daily for six months would cure AIDS.

    In 1992, Nation of Islam leader Louis Farrakhan said that his church had acquired the exclusive distribution rights in the United States for Immunex, a brand of interferon. However, Dr George Carlo, acting technical director of Pharma Pacifica Management Ltd. of Australia, which owns the Immunex trademark, said, "How could anyone give them the rights to distribute the drug? It's illegal to sell it in the United States."

1995 Mar 15: AIDS: USA Today also carries the story of the battle between Louis Farrakhan and George Carlo over Immunex under the headline "Miracle Cure for AIDS"

Carlo AIDS rebuttal

In a later widely-circulated e-mail answering his critics, George Carlo explains his involvement with Immunex and Pharma Group, in this way: "A company called Pharma Pacific asked me to help them with studies of oral interferon as a remedy for AIDS patients. I was their Acting Technical Director for the sole purpose of representing them on a multi-center clinical trial conducted by the National Institutes of Health.     I participated in that study at the NIH for two years, then stepped aside. there is nothing in that relationship that is a problem, especially since it was work sponsored by and paid for the National Institutes of Health. The work was done to help save the lives of patients with AIDS. I am not sure why your folks would find that offensive." Note that even at this time, Carlo couldn't bring himself to admit that Pharma Pacific was actually a Dow Chemicals phramaceutical subsidiary. The first NIH AIDS interferon trials had been done many years before Carlo became involved — between August 1982 and April 1984 in the San Francisco General Hospital. The NIH trials involving "Pharma Pacific", says that the project which began in April 1996 under Jones Kumi, of the Mercy Speciality Center in Detroit and closed a year later on June 13 1997. It was using a number of clinics to distribute the Low-Dose Interferon [including those of the Nation of Islam] and it was discontinued because too many of the study subjects dropped out. The report says that: Pharmaceutical support for the study was provided by Amarillo Biosciences, Inc., Interferon Sciences, Inc., and Pharma Pacific Management, Pty. Ltd. The inconvenient truth is that Carlo was listed as the technical director of Pharma Pacific and of Fernz Corp (NZ) for many years, and clearly acted as their US spokesperson. The Pharma/Fernz/NuFarm companies are subsidiaries of Dow Chemicals, but the Pharma/Dow connection wasn't revealed. Pharma used his Washington office and Florida apartment as addresses-of-convenience in the USA. The only reason for using Carlo's addresses is to hide the involvement of Dow.

1995 Apr 19: Chris Coggins at RJ Reynolds Tobacco was circulating "a paper by Carlo on the effects of subjectivity" This is obviously his Bias study.
[Note that Coggins doesn't need to specify which Carlo — clearly Carlo is now well-known to all his executives and lobbyists.]

    Coggins was building a junk-science story to be fed to the CBS "60 Minutes" program, and he was relying on evidence produced by George Carlo, [Peter] Huber, [Alvan] Feinstein, [Ernest] Wynder, and [Martha] Perske. attacking the EPA's use of meta-analysis and of exhibiting bias.

• Peter Huber, a lawyer-lobbyist at the Manhattan Institute had invented the term "junk science".
• Alvan Feinstein, statistician from Yale, received millions of dollars from the industry over the years
• Martha Perske ghost-wrote material for Milloy at TASSC, and also worked with Feinstein.
• Ernest Wynder, by this time he was working with Carlo and the tobacco industry attacking junk-science.

1995 May 12: A Washington Times column by Walter Williams "Highway to health serfdom" complains about the states recovering Medicaid costs from the tobacco industry, and says "America's anti-smoking tyrants have little respect for private property rights...."

    He carries on in a convoluted way to discuss raised breast-cancer rates among women who have had an abortion. He claims that young women who've had an abortion have 8-times the risk of breast cancer before the age of 45, and he then segues into a statement that:

George Carlo and his associates did a survey of 1,461 epidemiologists, toxicologists, physicians and general scientists on their thinking about secondhand smoke. Their study, published in the Journal of Risk Analysis, found that 70 percent thought secondhand smoke was a serious health hazard and 85 percent thought government intervention was necessary.

    What can be made of a scientific community that supports oppressive government regulations to combat secondhand smoke, which has a relative risk ratio of 1.19, and greets with skepticism a report showing an abortion-tnduced breast cancer relative risk of 1.3?

    The most flattering answer I come up with is that they are dishonest people willing to be prostitutes for an evil agenda.

1995 May 30: GEP: Thorne Auchter, as the Director of the Institute of Regulatory Policy [which was claimed to have commissioned Carlo's "Biased Scientists' study] writes on Federal Focus Inc letterhead to Philip Morris

Federal Focus is a non-profit 501(C)(3) organization which performs research and studies dealing in areas of current public policy. By this letter, we are requesting an unrestricted grant in support of those activities in the amount of $250,000.

    Federal Focus is most appreciative of your interest and willingness to consider this commitment.

1995 Oct: GEP and London Principles: The London Principles Conference. This was an attempt by the tobacco industry to build on work by the chemical industry in setting a ridiculously high standard of 'proof' for epidemiological research used by the regulatory agencies. This conference evolved from the Oct. 1994 Landsown Conference. It aimed to promote the standard called "Good Epidemiological Practices" or GEP, which they were then to force through the European Parliament.

GEP Guidelines and Criteria had already been drafted by tobacco lawyers Covington & Burling well before the conference took place so the outcome was assured. The rest was a PR exercise to put a veneer of scientific authenticity over their lobbying program. They also used these occasions to reward faithful scientific friends, and enhanse their citation lists:

Expert Panel Members

• John Ashby University of Wales, Swansea, and Zeneca Central Toxicology Laboratory.
• Dr George Carlo, The Carlo Institute and Health and Environmental Science Group, Ltd., and Professor, The George Washington University, Washington, DC, USA
  [At this time Carlo was also in the midst of the strike in his WTR cellular phone program for the CTIA. He was also promoting Nocebo conferences with Ernest Wynder of the American Health Foundation, and had other projects on the run for Dow Chemicals.]
• Dr Samuel M. Cohen, Eppley Institute for Cancer Research Omaha.
• John S. Evans, Harvard School of Public Health, Boston,
• John D. Graham,Harvard School of Public Health, Center of Risk Analysis,
  [Simultaneously running Carlo's Peer Review Board at WTR for the cellphone industry]
• Walter W Holland, University of London
• Linda C. Koo, University of Hong Kong
  [Long-term tobacco consultant and WhiteCoat]
• Genevieve M. Matanoski, Johns Hopkins and University of Maryland, Baltimore,
• D. Warner North, contractor with Decision Focus, Inc. Calif.
• Dennis J. Paustenbach, McLaren/Hart, California
  [science-for-sale grifter]
• Göran Pershagen Karolinska Institute, Stockholm, Sweden
• James J. Schlesselman, University of Pittsburgh,
• Thomas B. Starr, ENVIRON, North Carolina
  [consultant-for-hire]
• James A. Swenberg, University of North Carolina Chapel Hill,
• Mary Jane Teta, Union Carbide Corp. and University of Massachusetts,
  [Chemical Industry consultant]
• Erich Wichmann, University of Wuppertal Oberschleissheim, Germany
• Gary M. Williams, American Health Foundation
  [Carlo associate]
• Ernst L. Wynder, American Health Foundation.
  [Carlo associate]

London Principles Expert Panel

Executive order  

Low Risk Epidemiology
Epidemiology is very useful in its correct context
Depends on Biological plausibility
George Carlo — Society for Risk Analysis — study on toxicologist / comparison as whether prior knowledge of study influenced their analysis. Other low-lxx risks not easily accepted.

See Page 19

1995 Nov: /E Late in this year, the Federal Focus group (Auchter, Tozzi and perhaps Carlo) established a subsidiary called the Center for the Study of Environmental Endocrine Effects (CSEEE) [Probably for Dow Chemicals, or for a group of companies from the Chemical Manufacturer's Association]

    The CSEEE was a non-profit dealing with hormone mimics in water, and health effects of the kind caused by DDT-breakdown products, furans and dioxins and atrazine.

    The silicone breast implant rupture problem had triggered a fresh interest in the possibility of hormone-mimics/endocrine disrupters causing breast cancer among other problems — and that fed back into fears of auto-immune problems resulting from the silicone in breast implants. It all became very confused.

    This was not helped by the knowledge that the implants were made by the company which gave the world Agent Orange, and denied the obvious for 40 years. The guff at the web-site said that the CSEEE's...

"... basic mission is to provide the public with objective and unbiased information on the state of scientific knowledge regarding issues of 'endocrine disruption', and to conduct, or sponsor the conduct of scientific research in that area."

The core of CSEEE was an academic science panel made up of two scientists who are prominent in toxicology and pharmacology relating to the human endocrine system (Drs. William J Waddell and John A Thomas), and two in wildlife toxicology (Drs. William H Benson and Keith Solomon).

    This information was also sent to Philip Morris

Philip Morris document Federal Focus info

Federal Focus See biogs at page 42

  • Carlo was occupied during most of this year running the Wireless Technology Research (WTR) project for the Cellular Telecommunications Industry Association (CTIA) — See Part 5, but he still had time for Dow Chemical projects ]

Carlo's disclaimer email.

Breast Implant Public Health Project: "This project was very important work done in cooperation of the Food & Drug Administration and at the request of the Food & Drug Administration head at the time, Dr David Kessler.     We identified which types of problems from silicone breast implants warranted different types of corrective intervention — ranging from localized corrective surgery to implant replacement.     Dow Corning funded the work, but it was overseen by the FDA. The same model was later used in the WTR where industry money was used to support public health work regarding EMR but with government oversight.     The Breast Implant Public Health Project was ended in agreement with the FDA in 1995, when the project was completed to everyone's satisfaction." [Carlo's date is wrong. This was the company was only registered in November 1996 and it was still operating in 1998.]

1996 /E: As Director of the Breast Implant Public Health Project, Carlo co-authored a study on the risks of breast implant rupture sponsored by Dow Corning. Dow Corning which made silicon implants was a joint venture between Dow Chemical and Corning Inc. It was sued in the mid 2000s for personal damages caused by ruptured implants, but the actions were dismissed.

From London Principles to Good epidemiology Practices (GEP)

Tobacco's control of the London Principle's conference meant that the proceedings were fed to the industry lawyers (Covington & Burling) for legal drafting as possible legislation which tobacco lobbyists later tred to impose on the European and other parliaments. When translated into regulatory legislation they began to be promoted as GEP or Good Epidemiological Practice. It then became a project under Mayada Logue, with a budget of $150,000.     There is nothing wrong with these standards from a scientific perspective — provided you believe in always achieving the highest of possible scientific standards. The PR trick was to impose a ridiculously high and rigid standard for the science on the regulatory agencies (EPA, FDA, OSHA and their European equivalents). No longer could they regulate on a 'precautionary principle' when adverse evidence began to accumulate; they must now delay regulation until they had "proof beyond reasonable doubt." And the industry was always able to pay scientists of standing to deny facts and to sew doubt.     Government imposition of such slanted scientific principles would have prevented environmental and health agencies from ever effectively regulating any harmful substance until the proof of dangers was universally accepted... an impossible task in view of the ease at which industry bribes both officials and scientific experts. See the CMA's original GEP panel

1996: Elizabeth Whelan's scientific astroturf American Council on Science and Health (ACSH) also got into the Dow Corning silicon breast implant defence business by publishing a paper "Silicon Breast Implants: Why Has the Science Been Ignored?" It was written by the well-known penny-a-word hack journalist Michael Fumento.

    At the time Dow Corning was fighting the FDA's 1992 semi-ban on cosmetic use of silicone (as distinct from saline) implants.

1996 Jan 16: Chicago Tribute article "How the Media and Lawyers Stir Up False Illness"by Michael Fumento, journalist, tobacco lobbyist and TASSC associate of Steve Milloy and George Carlo. He also promotes the Nocebo effect and the safety of breast implants.

A nocebo is a negative placebo. That is, while a placebo pill makes you feel better though unbeknownst to you it's only made of sugar, a nocebo makes you feel bad though physiologically speaking it shouldn't be able to.

    Nocebos don't get talked about much, which is why the [Wynder's] American Health Foundation (AHF) recently called together a number of experts for a conference on the subject. For nocebos aren't just minor curiosities, but are wreaking havoc in America today.

• Gulf War Syndrome
• Love Canal dioxin and chemical contamination
• Silicone Breast Implants

  "For 30 years women were satisfied with implants," Emory University gynecology and obstetrics professor Dr Elizabeth Connell [of TASSC] told me.
  
      Connell headed the FDA panel that investigated the implants. "Lot of studies at the [FDA] hearings and since then showed a very high level of pleasure and acceptance and gratitude." But then the media and the lawyers got in the act. Newspapers and magazines ran stories with titles like "Ticking Time Bombs," "Toxic Breasts," and "After Implants, Horror Began."
  
      Suddenly women with implants were suffering all sorts of strange illnesses and "realizing" that illnesses they already had must be related to their implants. "When you have women being told they have ticking timebombs in their breasts, what are they to think?" said Connell.

1996 Feb 16: [Source Public Health Weekly article, undated] Carlo writes on behalf of the " Institute for Science and Public Policy Polio Vaccines Advisory Panel" to the American Committee on Immunisation Practices (ACIP — which advises the US government on immunisation programs. (He owns and controls the ISSP)

    His letter promotes the continuation of past immunisation practices.

"The Institute for Science and Public Policy Polio Vaccines Advisory Panel met February 16, 1996, as part of the most comprehensive review to date of the public health impact of changes to the polio vaccine recommendation currently used in America. The independent institute advisory panel, which expects to complete a report for the peer reviewed medical literature within 45 days, is comprised of prominent international scientists, top state health officials, infectious disease and epidemiology experts, and other noted academicians.

... that the institute's panel "has expressed reservations about an immunisation schedule that involves the addition of inactivated polio vaccine (IPV) administered as a separate antigen."

    He added "there is unanimity among the advisory panel members that the proposed change in the current polio recommendations poses a significant risk to public health by compromising vaccination coverage overall and reducing needed protection against wild polio virus transmission."

    Wild polio virus is endemic in many parts of the world and remains a worldwide public health threat. In commenting on the scope of the work regarding potential changes in the country's polio vaccine policy, Carlo said "we are involved collectively in an unprecedented and critical public health process. The potential impact of this policy change on global public health commands that all relevant information be thoughtfully considered in the decision making process."

    The letter and attachments to ACIP are available upon request by telephoning the Institute at 202-833-9500. (Public Health Weekly, undated)

1996 Mar 23: A Philip Morris technology strategy document (from a brainstorming session) lists numerous ideas for coordinating a wide range of activies of both domestic/international tobacco and food companies under the heading "Potential Areas for PM-wide Synergies" This includes a number of non-technology ideas...

• Special topic leadership and sponsorship, e.g. use of epi data and meta studies, risk assessment, the NOCEBO effect, etc. [The Carlo-Wynder speciality]
• Good/bad science. [Another Carlo speciality]
• Nutrition and health. [A Wynder speciality]
• Monitoring regulatory activity as it could impact our products/packages/ processes and the use of technologies e.g., genetic modification
• Biotechnology strategies

1996 Aug: London Conference and GEP: A pre-publication version of the London Conference document "Principles for Evaluating Epidemiologic Data in Regulatory Risk Assessment." was sent to Philip Morris.
[This is a printer's page proof, sent requesting final approval]

The principles and recommendations for both existing and future epidemiologic studies drafted by the conference participants are presented in this report verbatim. Other portions of the report, such as the Executive Summary, the Background section, the Preambles to the principles, the summaries of the discussions regarding the specific principles, and'the appendix describing the Bradford Hill criteria, were drafted or compiled by Federal Focus staff after attendance at the conference and full review of the conference transcripts and conference materials.

    Federal Focus staff present at the conference were Thorne G. Auchter, William G. Kelly, Jr., Suzon Landeck, and Wayne D. Ploger of Wayne Ploger and Associates. Mr. Kelly had lead responsibility for compiling this report.

[Long document of 127 pages ]

1996 Nov: Breast Implants: By mid 1997 Carlo was listed as the director of the "Breast Implant Public Health Project" (BIPHP), and the organization was being run out of the HES and WTR offices in Washington DC. Dow Corning Corp funded it to the tune of $1.3 million.

The BIPHP is dealing with problems like scar tissue and causes of implant rupture, and the project states that "at this time" it will not address the controversy over the risk of systemic disease.

1996 Nov 11-13: Carlo was in Australia at University of Melbourne speaking to the 4th International SciComm (Conference of Science Communicators) meeting on 'Risk Assessment'.

    He had been offered as a keynote speaker to the conference gratis by Pharma Pacific Management Pty Ltd. Carlo was credited as their Technical Director and they paid his expenses, but said nothing about his (or their) associations with other public-health risks. Pharma promoted vaccines, and their associated company NuFarm was the Oceanic manufacturer of Monsanto Chemical's Roundup herbicide. These were all Dow Chemical subsidiaries.

    [A month later (Dec 27), The Age newspaper in Melbourne reports "Commonwealth to Tackle Low Immunisation" This is a multimillion dollar immunisation program which was to be launched in January 1997.

Breast Implant Public Health Project (BIPHP) is registered by Carlo as a Deleware company.

The Breast Implant Public Health Project, LLC is registered as a private startup company incorporated in Wilmington, Delaware on the 6th November 1996 by "The Corporation Trust Company"     It is funded by Dow Corning to do a number of literature and psychological profiling studies of breast implant problems. The pilot study's goal was to test the feasibility of a data collection form which will be used in a scale-up study analyzing multiple surgeons' records.     The goal of this expanded study will be to develop identifying factors for women who are at greater risk for having ruptured implants and, if necessary, target them for screening, surveillance, or intervention. Published as A review of the literature on the etiology of capsular contracture and a pilot study to determine the outcome of capsular contracture interventions. Factors associated with breast implant rupture: pilot of a retrospective analysis in May 1999] An 2002 article on "Mental Models of Women With Breast Implants: Local Complications" deals with profiling the psychology of women with implants by the BIPHP team led by Martha Embrey. [Martha Embrey who ran BIPHP for George Carlo, was a long-term employee of HES]     The article gives details which suggest that this is a project being run by George Washington University — and leaves out any mention of Carlo's Deleware LLC. The Breast Implant Public Health Project provided financial support for this study through a grant from the Dow Corning Corporation. We wish to express our thanks to Liz Adams, Barbara Blasick, Julie Downs, and Susan Houston for their help with the conduct of this research, as well as to anonymous reviewers. The views expressed are those of the authors.     NOTE For further information, please address communications to Martha Embrey, MPH, Department of Environmental and Occupational Health, The George Washington University School of Public Health and Health Services, [Martha Embrey is also listed as being a "research associate" at the University. She was one of Carlo's long-term employees at Health & Environmental Sciences Group who was also associated with the university (as also was Carlo himself).

1996 Dec 2 - 4: Carlo and Ernest Wynder of the American Health Foundation have convinced Dr Wayne Jonas of the National Institutes of Health to join forces with them in promoting the idea of the 'Nocebo' at a 3-day conference. This is an old idea, but it has been given new currency by the use of a catchy name-variation, based on 'Placebo'.

Nocebo, is the idea that people make themselves really ill because they believe something is harmful (when it actually isn't). It provides polluters and poisoning companies with a possible alternate 'causal' mechanism to deflect blame away from their products. Note the listed headings for the conference: "Mass Hysteria, Psychosomatic Illness, etc"

    This has implications for tobacco, chemicals and the cellphones, and for many other industries, The popularisation of a term like 'Nocebo' provides these industries with another line of defence... another way to create doubt about 'cause and effect' relationships between their products and the health problems they may (or may not) cause.

See Original Conference on Nocebo with NIH

1997: The Carlo Institute is running a six-session $650 course with topics like "Media Relations" and "Effective Management of Research Funds".

1997 Feb 18: Dr Wayne Jonas of the National Institutes of Health appears to have dropped out of the Carlo-Wynder 'Nocebo' conference. It is now being promoted only as a one-day event for a cost of $295. It is being held at Georgetown University, but without the support of the NCI.

    Carlo and Wynder have now enlisted disinformation journalist Michael Fumento (also of TASSC), along with Dr Richard Adamson from the National Soft-Drink Association (ex NCI Division of Cancer Epidemiology — also on the AHF Board of Directors) as speakers.

See Second Conference on Nocebo at Georgetown

1997 March: Steve Milloy took over officially as 'Executive Director' of The Advancement of Sound Science Coalition (TASSC). He had previously been hired as the 'behind the scenes contact' who could answer press questions. For a while Garrey Curruthers continued to parade himself as 'President' and 'Founder'.

    The so-called Management Board listed in the TASSC letterhead was also sometimes called an "Advisory Board" [Not a SAB], and different listings had different names at different times. Carlo's name never appears on the letterhead, but he is listed by APCO (the PR company which ran the operation behind the scenes) as a member of the Scientific Advisory Board.

    This Advisory Board appears to have consisted of a variable list with at least 7 well-known tobacco industry 'consultants', only a few of which were 'scientists':

• Mickey Edwards, Republican politician
• Michael Gough, OTA scientist/dioxin now with Cato Institute (Milloy's friend)
• James Steele, ex-Ass. Surgeon General,
• Bruce Ames, Berkeley biochemist, libertarian zealot
• Michael Fumento, journalist-for-hire
• John D Graham, Harvard Center for Risk Analysis
• Lester Lave, Carnegie Mellon economist, HCRA associate,
• M Alice Ottoboni, retired from the Calif Dept of Public Health,
• Frederick Seitz, ex-Rockefeller Uni; professional climate skeptic; Oregon Petition; George C Marshall Institute; SEPP; RJ Reynolds consultant
• Clayton Yeutter, trade representative and Sec of Agriculture; politician for hire.

• George Carlo, of HES
• Hugh Ellsaesser, retired meterologist; Lawrence Livermore nuclear labs; George C Marshall Inst.; "Wise Use" group; climate denier
• Patrick Michaels, Uni of Virginia; SEPP; climate skeptic; fossil fuel consultant
• Alan Moghissi, science-for-sale operator; ILSI; ACSH
• Michael Fox, dubious nuclear scientist; newspaper columnist; ACSH; climate denier
• S. Fred Singer, SEPP; ICSE; Heidelberg Appeal; chief climate denier
• Michael Sanera, Barry Goldwater Institute; ALEC; Reagan Admin aide; 'Wise Use' coalition founder,

• launched a full-scale attack on restrictive air-quality standards, with an full-page ad in The Washington Post signed by 100 physicians and scientists.
• releases an open letter to world leaders signed by 500 physicians and scientists attacking the Kyoto Conference global warming treaty.
• attacked the EPA for its use of guideline standards of epidemiology which are inferior to GEP.
• held a junk-science conference in Phoenix, and a media summit on health scares at the North Carolina State University run by TASSC enthusiast Dr Robert Entman. [Entman was a professor of Journalism. TASSC had previously sponsored his report on The Role of Science in Reporting of Public Health Policy Controversies During 1995.]
• ran roundtable meetings for lobbyists and a series of editorial board briefings on silicone breast implants, hosted by Dr Elizabeth Connell. [She also travelled to the UK to lobby the new Labor British Health Minister.]

1997 Mar 16: An article in the Toronto Star by Carlo associate, Professor Keith Solomon of Geulph University is in support of the tobacco companies. He is quoted as saying that gun-shot wounds were more of a problem than second-hand smoke. Solomon is also a consultant to companies in the pesticide industry.

1997 June 20: Several State Attorneys General had concluded an agreement with the tobacco industry which required signing off by Congress. However Congress appointed an Advisory Committee on Tobacco Policy and Public Health to advise it.

    This committee was chaired by former US Surgeon-General C Everett Koop and former FDA commissioner David Kessler [both fierce opponents of the tobacco industry]. And it issued its final report to Congress in July 1997.
Guess who provided the staffing for this 'committee'?

    The clue is in the advice that printed copies can be obtained from The Advisory Committee on Tobacco Policy and Public Health at the old HESG fax number of 202/833-2801 or by email from sppi@hesgroup.com http://www.ncbi.nlm.nih.gov/pmc/articles/PMC175956 (etc.) [Koop and Kessler would have been entirely ignorant of the fact that an old tobacco scientist was running their committee. It would be intriguing to know how this was engineered.

    One clue might be that the anti-smoking Republican Jeff Nesbit was given the job of staff director of the committee staff (three from HES). He had been a CTIA public relations operator who acted as a go-between with Carlo and the WTR, and he was once the FDA communications aide for FDA Commissioner Kessler. David Kessler credited Nesbit with convincing the FDA to regulate the tobacco industry in the early 1990s ("A Question of Intent").

    Nesbit is also listed in the report as "President, Science and Public Policy Institute" — so one of George's lobbying operations was also part of the decision-making process, along with a score of genuine anti-smoking and government health groups.

    Nesbit appears to have retired from SPPI the day after the report was printed and George Carlo became president again. "For more than a decade" (1992 - 2004) Nesbit was supposedly the president of The Shiloh Group —a strategic communications firm that he founded and ran. He also runs Invivodata.Inc which is used in hospitals to collect patient information

    Add to this is services as an aide for VP Dan Quayle and Elizabeth Dole, and his services as a lobbyist via the Citzens for a Sound Economy (FreedomWorks), and authorship of a dozen novels, and we clearly have a man of many talents.]

1997 Oct: Epi Monitor reports on a plenary session "The Battered Investigator Syndrome" held recently at the American College of Epidemiology meeting in Boston.

    In that session, investigators involved with breast implants, gulf war syndrome, electromagnetic fields, and induced abortion and breast cancer discussed the difficulties they faced in working in these controversial areas.

As epidemiologists and epidemiological research have become increasingly integral to tort litigation, the authors report that epidemiologists have themselves become targets of onerous subpoenas and lawsuits.
"It's a new ball game," [Rebecca Steffens and George] Carlo told the Epi Monitor. "In the past, there were always attacks but they took place within the arena of peer review. What's new is that opponents are now making the epidemiologists personally liable. It is the ultimate intimidation. When a person's professional and personal livelihood are at stake, it impacts them and it's not business as usual. It will cost $200,000 - 300,000 to defend yourself. Some will quit," he said.

    Other examples cited by Carlo include two lawsuits which he has been involved with at a cost of $700,000 to defend. One cost $100,000 simply to get it dismissed. In his situation, the legal costs were borne by Wireless Technology Research, a group he is affiliated with.

    However, he knows of another suit in which the epidemiologist was sued personally for the way in which he defined a cohort for his study. In that situation, his employer reportedly refused to pay his defense costs. In another situation, an epidemiologist who had already conducted research was reportedly forced to discontinue doing research on this particular topic because her employer considered the liability too high.

    According to Carlo, when you get subpoenas it can take months to prepare a deposition. This wastes a lot of time and money and keeps you away from your regular work. Others are defining your priorities. In the legal arena, the trend is to do whatever you need to do to win. In the legal framework, that is fair game, according to Carlo.

    Besides the professional liability insurance, another safeguard suggested in the paper is the inclusion of indemnification language in research contracts. "Such a clause would ensure that the sponsor of the research is responsible for the costs of litigation, including attorneys' fees and any potential liabilities or judgements," according to the paper. Finally, professional associations should become active in monitoring for adverse trends and in organizing interventions at an early stage. "It cannot be assumed that the field of epidemiology is above the fray —where billions of dollars in claims, legal fees, and awards are involved, all bets are off," conclude the authors.

1997 Oct 27: Breast Implants: Jeff Silva article in RJR "Harvard Peer Board Frustrated with WTR: Carlo to study implant risks" Silva comments on the problems of the Wireless Technology Research (WTR) project for the cellphone industry, and how Carlo is looking at other potential sources of income.

Dr George Carlo is quietly ramping up a new industry-backed health program on possible silicone breast implant health risks that is based on the troubled WTR model.

    The "Breast Implant Public Health Project LLC" is one of several endeavors Carlo and his 30-person crew oversee at Health & Environmental Sciences Group Ltd. here.

    Just as Carlo teamed with the Cellular Telecommunications Industry Association (CTIA) in early 1993 when fear of pocket phone-related brain cancer was at fever pitch — and again in the early 1980s, with the Chlorine Institute on the dioxin debate, the embattled WTR chief now has joined forces with Dow Corning Corp, the leading breast implant maker, to delve into one of the hottest women's health issues today. Dow Corning has given Carlo $1.3 million to date.

    Whether science ultimately declares cell phones, silicone implants and dioxin to be major health problems is another question. But where there is health controversy, Carlo seems to be near.

1997 Nov: Breast Implant: Microwave News, a journal which keeps its eye on Carlo's various get-rich-quick schemes, pointed out that the Breast Implant Public Health Project (BIPHP] shared the same phone number as Carlo's HES and WTR. The BIPHP received $1.3 million from Dow Corning, but the focus was only implant rupture and scar tissue formation, and largely avoided systematic immune system reactions. Despite Carlo's "reports," Dow Corning filed for bankruptcy and the FDA subsequently banned silicon breast implants for 15 years.

1997 Dec: Breast Implants: Martha Embrey spoke at the Society of Risk Analysis Annual Meeeting:

Abstract: Local Complications from Silicone Breast Implants.

    The Breast Implant Public Health Project's goal is to develop and carry out a public health approach to help women identify and remedy localized problems derived from their silicone breast implants. This public health program has been initiated to provide a remedy for known problems and in anticipation that the public, government agencies, scientists, and industry will use the results and findings.

    The work done under the program is not intended to identify risk, but to find ways to best characterize and mitigate risk that has already been established. The existing scientific evidence supports the hypothesis that women with silicone breast implants are at risk of local complications including rupture and capsular contracture; therefore the research plan simultaneously addresses the questions related to risk characterization and intervention, so that appropriate risk management recommendations are available. The research agenda will be the basis for developing requests for proposals that address specific research issues important to managing any public health or clinical risk from local complications.

1997 Dec 10: A Society for Risk Assessment paper "Airborne Particulate Matter and Environmental Ozone." by Claudine M Johnson and EE Adams, both from Carlo's Health & Environmental Sciences Group, attacks the EPA over its enforcement of Clean Air Regulations.

The premise that further lowering of the particulate matter (PM) and ozone standards as proposed by the Environmental Protection Agency (EPA) will accrue a greater protection of public health is not only inconsistent with scientific and medical data, but runs contrary to the tenets of public health protection.

    While the rationale for the new standard has been put forth by the EPA as enhancement of public health, in reality this rationale is disingenuous. Quite to the contrary, it is likely that a detriment to public health will follow from the misdirecting of resources that could be applied to public health protection and the misinforming of the public about the causes of such problems as asthma attacks and chronic obstructive pulmonary disease.

    The appropriate regulatory decision tree for protecting the public from the adverse effects of exposure to high levels of particulate matter and ozone involves the standard public health paradigm. While the EPA standard setting procedures lay the groundwork for primary prevention or minimization of exposure, public health protection can only be accomplished with complementary, disease based screening and corrective intervention —in other words, secondary and tertiary prevention.

    The implementation of these critical protection steps goes beyond the abilities of the EPA, and must include the professional public health and medical communities. With this background work in hand, and documented in a scientifically sound support document, a public forum can be sought whereby this approach to public health protection can be brought forth as the appropriate remedy for the problems that have been highlighted by the EPA regarding PM and ozone.

1997 Dec 10: Susan O'Donnell of HES is presenting a paper at the Annual Meeting of the Society for Risk Analysis in Washington. It is an attack on an EPA proposal for stricter standards.

    The HES paper is claimed to be unfunded, however it "was prepared in response to interest from a Washington consultant". It deals with "airborne particulates and ozone."

1997 Dec 20: Steve Milloy at The Advancement of Sound Science Coalition (TASSC), is now taking an interest in debunking the science investigating possible links between cellular telephones and health.[along with denial of ETS, global warming, etc.]

    Carlo is a member of TASSC's Scientific Advisory Board. TASSC is primarly funded at this time by the tobacco industry, but with some support from Exxon and the oil industry, Dow Chemicals and now the Cellular Telecommunications Industry Association (CTIA).

1998 Apr 3: The end of the GEP program.

GEP: Well over a year after Carlo had ceased working for them, Philip Morris finally decided to withdraw support for both GEP and the associated ASEAN conference. [which had been assigned to Myron Weinberg's consultancy group]

Ted Sanders of PM Europe, wrote to Cathy Ellis (PM's principle scientist/lobbyist in Brussels) stating his objections to GEP with its enormously wasteful expenditure. He had been lumbered with trying to make something out of the project, and in the letter he outlines the full history of GEP.

Approximately three years ago, the concept of GEP's was discussed in considerable detail in PM. Corporate Affairs thought it was a wonderful idea, because at first they felt that part of a code for Good Epidemiological Practices would state that any relative risk of less than 2 would be ignored.
[Most passive smoking studies came out with RR figures which were under 2.]

    This is of course not the case. No epidemiological organization would agree to this, and even Corporate Affairs realizes this now. [snip]
[Despite constant corporate propaganda, relative risk figures can't be treated in this simplistic way. And every epidemiologist and biostatistician knows this.]

    John [Rupp of Covington & Burling], with the help of our old friend Myron Weinberg [of WashTech], put together a consortium of companies in France who were interested in the idea of GEPs. This consortium, headed by an epidemiologist at Dow Chemical France, put together an excellent code of Good Epidemiological Practices. The first public presentation of this code will be on April 23 in Graz at an epidemiology meeting which I will be attending.

    John has also been carrying out considerable lobbying (by himself or through others I don't know) an organization called ADELF which stands for (after translation and rearrangement) the Organization of French Speaking Epidemiologists. It has been John's goal to assure acceptance of the consortium code by ADELF. John has also initiated similar activities in Italy and Germany. Total expenses for this program in 1997 were about $300,000.

    Aside from the fact that I continue to receive GEP bills from all sorts of places for old work (the latest is from Sweden, and none of them is parflcularly large), I recently received a bill from John himself for work done in the month of May. My understanding from conversations with Richard [Carchman], Matt Winokur, and Paola de Kock was that no further work was to be done on GEP's, and that John was in agreement with that decision.

    After I received the bill, I spoke to John Rupp himself. His impression was that Denise Keane had authorized him to continue the program, although only with
    respect to what he was doing in France. In other words, the program would not be expanded to other countries.

Ellis replied agreeing with Sanders, and the GEP project was finally closed. It had had a eight year run from the time of George Carlo's original Bias study.

1998 May 1: Martha Embrey, George Carlo and three surgeons (who only provided access to their files) presented a paper at a plastic surgeon's meeting "Factors Associated with Breast Implant Rupture: Pilot of a Retrospective Analysis" funded by the "Breast Implant Public Health Project"
[No mention of Dow Corning.]

    After all these years they had only got to the stage of "testing the feasibility of a data collection form which will be used in a scale-up study analyzing multiple surgeon's records" A total of 92 records had been collected and analyzed to "identify factors for women who are at greater risk for having ruptured implants."

The same crew had also produced: "A Review of the Literature on the Etiology of Capsular Contracture and a Pilot Study to Determine the Outcome of Capsular Contracture Interventions"
[One puff piece on the web says that in July 2008: "These studies found silicone breast implants to have possible long term health..." (it didnt say?)]

Federal Focus's London Principles Revision

GEP: In July 1998 Federal Focus claims to have set up a one-day, six-man panel in Denver, Colorado to review and redraft the London Principles. The panel consisted of: David Savitz EMF researcher; top epidemiologist; Dr Christine Friedenreich — also at the Lansdowne Conference. William Waddell (who merely teleconferenced into the panel discussion for a short while). He was chairman of the Science Panel for Federal Focus's Center for the Study of Environmental Endocrine Effects. The others are inconsequential. Tozzi makes the claim that "This project was financed solely by Federal Focus, Inc., and was not supported by any grants or specific contributions." ... and if you believe that, you'll also believe in tooth fairies.

1998 July 15,: the House Subcommittee on Energy and Environment held a hearing entitled, "The Science of Risk Assessment: Implications for Federal Regulation," to examine the state of risk assessment in the Federal Government and how it might be modified to better protect public health and safety.

    Legislation before both houses of Congress have proposed to change the way the government evaluates risks and then creates and enforces regulations to protect the environment, and public health and safety based on those risks.Witnesses included:

• Dr Gil Omenn, Chairman, the Presidential/Congressional Commission on Risk Assessment and Risk Management and Executive Vice President of Medical Affairs, University of Michigan;
  [He took over from Thorne Auchter.]
• Dr George Carlo, Chairman, the Science and Public Policy Institute, George Washington University;
• Dr George Gray, Deputy Director, Center for Risk Analysis, School of Public Health, Harvard University;
  [John D Graham's deputy]
• Dr Lois Gold, Director, the Carcinogenic Potency Project, National Institute of Environmental Health Sciences (NIEHS), Center for Environmental Health Sciences, University of California, Berkeley, and Senior Scientist, Lawrence Berkeley National Laboratory
  [She is the partner of Bruce Ames]

See transcript.

1998 July 15: Congress (House) hearing of the Subcommittee on Energy and Environment, "The Science of Risk Assessment: Implications for Federal Regulation"

    At this hearing Carlo claimed that the Science and Public Policy Institute (SPPI) — a tax-free non-profit [501(c)3] which Carlo was beginning to use as his primary business organisation — was housed at "George Washington University." Carlos statement says:

Thank you, Mr. Chairman and other members of the Committee. My name is Dr George Carlo and I am the Chairman of the Science and Public Policy Institute at the George Washington University School of Public Health and Health Services. I'd like to put in a plug for George Washington University. While not the University of Michigan or Berkeley, we are a new school of public health and we intend to make our mark as well.

    I'm an epidemiologist by training and also have some legal training and, over the past 20 years, I've been involved in work ranging from assessing the health impacts of pesticides and cellular phones to the safety of pharmaceuticals and medical devices. And, one of the things that we are now doing at the Institute is researching a comprehensive book that lays out trends in both environmental and public health legislation and the ability of those legislative actions to protect public health.

[A]nother thing that we've found is that the information threshold for the general public is very low. And in that 80/20 breakdown, that 80 percent of the population [the silent majority], when you present them with a list of chemicals — like in a right-to-know or a toxic release inventory — what you do is you begin to move that 80 percent into the 10 percent [the active advocates for-or-against a chemical/company] on either side.

    Just by having that [inventory], causes agitation; by having that, causes fear among the population. And I know this is a very difficult area, because it sounds like keeping information from the public, but what we've identified—we don't quite have a solution for it yet—is that by releasing information you create public health anxieties.

    It's not public health education that this is promoted as. It is agitation among the public, because they don't understand what it means, and that in and of itself becomes a public health problem.

Dr George L Carlo is an epidemiologist and chairman of the Washington, DC-based Health & Environmental Sciences Group, ltd (HES Group). HES Group specializes in assessing and managing risks to human health. He has served in many scientific advisory capacities and, from his faculty position at the George Washington University, heads the nonprofit Science and Public Policy Institute.

    The coauthors are:

• Susan E Hersemann, the Director of the Institute
• Claudine M Valmonte, MA, is a research associate [ex Claudine M Johnson]
• Kathleen Kapetanovic, JD MPH is an associate director of Public Policy with HES Group.

1998 Aug: He is listed in this Washington Legal Foundation 'Critical Working Paper" as Professor George Carlo, Science and Public Policy Institute, George Washington University. [Carlo wrote papers for the WLF himself]

Page 15

1998 Nov: /E Carlo is now concentrating on the Breast Implant Public Health Project for Dow Corning. The WTR is being wound down, and replaced by a public relations organisation called WIN.

1999 Nov 1: Corporate Crime Reporter newsletter announced an interview with George Carlo, President, Health Risk Management Group, Washington, D.C.,
[Note the reappearance of the 'Health Risk Management Group' organisation name. This is the one based at his apartment in Florida.]

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