Document 2bN3mvp3mwMQLBM1wDpB4a5p

TO: FROM: AXkfcSl OS li\TERNA'HONAL ASSOCIATION (Limiicd by Go.j.r.mtoe) 68 GLOUCESTER PLACE, LONDON WiH 3HI- Member Associations MEMORANDUM _____ e. il X / AIA/41/NEWS Director-General August 1980 AIA .'NOTES FOR ASSOCIATIONS 1. The previous issue of these notes was in July 1979; the subsequent twelve months have been marked by a number of events each of considerable significance to the asbestos industry:- (a) Publication of the long-awaited report by the UK Advisory Committee on Asbestos (ACA). (b) EPA and CPSC proposed rule making on asbestos, and AIA/NA reaction to this (USA). (c) Proposed legislation concerning dangerous substances in Germany. (d) Confirmation of the anti-asbestos legislation in Denmark. (e) The IARC conference at Lyon in September 1979 at which the ScAP met for the first time. (f) The QAMA-sponsored meeting at Montebello, PQ. 2. Details are included in relevant paragraphs; to enable busy readers to select the items which interest them the Notes are indexed. 3. As Members will now be aware, much of the work of the Association devolves on the ten Panels whose task is to advise the Executive Consnittee (Chairman Dr. Gaze). Using this information the Executive Committee takes necessary action with authority derived from the Governing Council (Chairman Mr. van der Rest). 4. Members might like to be reminded that the Panels' advice can vary from the highly technical to the semi-political. For example, the EEC Advisory Council enables industry to be warned when matters concerning asbestos are being considered in the EEC Institutions; this gives industry an opportunity to make its voice heard. Dust measurement is a critical issue for asbestos and the Dust Measurement Advisory Panel enables us to bring to bear on the subject the highest possible quality of scientific expertise. In matters of medicine our industry doctors try to achieve an identity of views through the Medical Advisory Panel, and our Scientific Advisory Panel gives us the considered opinion of eminent outside medical specialists on UCC 014586 A07396 n AIA/AI/NENS V JULY 1980 AIA NOTES POD ASSOCIATIONS ITEM C 0 IT T E N T S ACTIVITIES OP PANELS EEC MATTERS NATO LABELS WASTE MEMBERSHIP COrTFERZNCES LOV.-DOSE INVESTIGATION RADIOGRAPHIC INVESTIGATION ACC-IH UICC/ILO X-RAY PILM AIA ADVISORY DOCUMENTS USEFUL PAPERS SELECTED REPORTS FROM COUNTRIES J.5. nE'ORIIATICN NEEDS ' PARAGRAPH 1-21 22-39 40 41-43 44-45 46 47-55 56-58 59-62 63-64 65 66-69 70 71-113 ATTACHMENT A073-97 UCC 014587 Member Associations AIA/41/NBvS August 1980 2- - our problems. Advice on how to put the AIA viewpoint to governments, the public etc. comes from our Communications Advisory Panel. The names of the remaining six Panels clearly indicate their function. The items in these notes owe much to information which has appeared in: AIA/NA's News & Notes; the QAMA Bulletin; the Amianthus Information Bulletin and the magazine "Asbestos" - to all of whom many thanks. Sir Neville Stack Director-General cc: Governing Council Executive Committee Chairmen of Panels CAP Members NOTE: Because of the difficulties of knowing how many copies to send each Member Association, together with the administrative load which would be imposed on my small staff, I am sending only one copy to each Association in the hope that further copies can be made as needed UCC 014588 AIA/Al/NEV^ JULY 1980 A. I. A. MOTES FOB ASSOCIATION (For Period July 1979 - July 1930) EEC Advisory Council (EAC) (Chairman Mr. 1C. Thi-ele) Six meetings were held during the period. A recent meeting was held in Aalborg when the opportunity was taken to visit the Dansk Etemit Factory. The 16th meeting was held in Milan - a visit was made to the Ealangero mine and delegates also met representatives of the Italian asbestos industry. Details of EAC business are shown at paras. 22 to 59 below. Dust Measurement Advisory Panel (DMAP) (Chairman Dr. K. Robock) This Panel has held three meetings during the period: these were held in Meuss, Costa Bica and Cannes. The IMAP produced the Standard Reference Method (RTHl) f see para. 66 below^ in tine for the Lyon Conference and is now addressing itself to the problem of-hneasuring the dust content of ambient air and of dust emissions from factories. The DHAP sponsored the recent successful Third Dust Colloquium at Cannes on 10/ll/l2 June 1930 (see paras. 52 and 55 below) which was hosted by the Chambre Syndics)? de l'Aniante (CSA) France. The next DMAP meeting will be on 5/4/5 September I960 at Denver, Colorado. The Medical Advisory Panel (MAP) (Chairman Dr.S.F, KcCullarb) There have been two meetings of the MAP (their 3rd and 4th) in the period. The paper on standardising criteria for the diagnosis of asbestos-related diseases is nearly complete. The drafting of an agreed format for recording the health data of work people has brought to light the difficulty of reconciling the numerous recording methods already in use by member companies. After reviewing this difficulty the Executive Committee has decided that the problem of compiling a standard health-recording form (since it also involves the recording of dust levels) should be incorporated in the work of a special study group on epidemiology to be chaired by Dr. Hobock. The Study Group's terms of reference are: "To make recommendations on what the AIA should do to encourage Member Associat'ons to:- UCC 014589 A07399 - 3- (a) Undertake more epidemiological investigations. (b) Facilitate the uniform collection of data." 6. It has "been further decided "by the Executive Committee that the IMP'S tasks should be made less burdensome by making their terms of reference more specific and reducing them in number. These are now to be;- "1. To standardise the criteria for the diagnosis of asbestos-related diseases (this task is nearly finished - para. 3 refers). 2. To advise on suitable Conferences for attendance by AIA representatives, (this is an on-going requirement.) 3. To make recommendations to the Executive Committee concerning the training of doctors involved in the diagnosis of asbestos-related disease - this will involve the interpretation of X-ray pictures and the results of lung function tests, (this is a new task.)" 'Hie Building and Construction Advisory panel fSCAr) (Chairman fir. Y. Alexandre) 7. The BCAP has now held five meetings all of which have been involved in discussing various drafts of an Advisory Document which lists tools for use with asbestos cement. (See para. 67 below.) These tools have first been tested at the Asbestos Institute at Neuss under conditions which simulate on-site work. This has been a most demanding task since great accuracy is required and a large number of tools have had to be tested. Me owe a considerable debt to Jir Teichert and the Asbestos Institute at Neuss. Acknowledgements and thanks are also due to those who have sent tools for testing from as fax away as the western TJ.S. and eastern Australia. 6. It was hoped to have a draft of the Advisory Document ready scon for consideration by the Executive Committee but final agreement within the Forking Party is proving more difficult than expected. The Fibre Producers Advisory Panel (EP/.T)(Chairman Mr. l.?.ri.Zrtchesr-\ 5* Following the Panel's meeting in June 197S all major western fibre producers now show the "a" logo on their bags. This is a UCC 014590 A 0740c considerable achievement and the AIA has written to the concerned Commissioners of the EEC so to inform them. The AIA has also been in touch with Rhodesia, Russia and Yugoslavia, to try and persuade them to follow suit. The new advisory document "Asbestos Fibre Handling" (?.CP 4) is now issued (see para. 66 below) and the first draft for the document on "Bag Opening" (see para. 67 below) has been written. The Communications *dvisorv Panel (CAP) (Chairman Hr. C.E. uatty) This Panel has nov had seven meetings. Following its recommendations both an "Industry Statement" and an "Information Digest" have been produced in pamphlet form (see para. 68 below). The CAP has recently been asked by the Governing Council and the Executive Committee to progress recommendations made at the April I960 Eontebello. Conference in Quebec on "Communications & Asbestos" (see paras. 50/51 below). The CAP has endorsed and the Executive Committee has now approved certain recommendations of the^ Montebello.Conference. Chief of these are: 1. To hold a special Yforld Conference on asbestos & health during 1961* 2. To assemble all papers concerning asbestos & health (this task is being undertaken by IHDA*). 3- To devote half a day of the 1961 Biennial Conference to Communications. 4. Countries who have not already done so to be advised to conduct a review of their national asbestos A health situations. 5. To have an AIA/KA member on the CAP. The CAP continues to advise the Executive Committee on immediate communications issues ana has played an important part in drafting AIA. comment to the OK ESE cn the ACA report (see para. 101 below). Institute for the Research Development of Asbestos - (A QJdvJQuebec Government-funded Institute.) UCC 014591 A74Q; Friction Materials Advisory Panel (FHAP) (Chairman Mr. H. Doussier) Two advisory documents on Friction Materials are nearing completion together with a background "position paper" on the friction material industry. At the first FKAP meeting held at Cologne on 22 April 1980 the most recent draft of the position paper was agreed and this has been sent for a second look to Executive Committee members for their approval. The second FMAP meeting wao held in London on 23 July 1980. Scientific Advisory Panel (ScAP) (chairman hr, J.C..Gilron^ The Panel met for the first time on 28 September 1979 after the IARC meeting at Lyon (see paras. 47/49 below) and thirteen out of the full membership of fourteen attended. As the total membership included scientists from as far away as Australia, Canada, Japan and the J.S. this was very gratifying. The ScAP made two main recommendations enlarged on at paras. 16 and 19 below. Firstly the Panel strongly advised the industry to assemble data on^areas of low dosage. They suggested that this could be done by locating a factory, mine, mill or other site where low dust levels were considered to have existed for a long time and where the work force was of a reasonable size for a worthwhile investigation. V.*hen such a plant had been located it should become the subject of a study which might veil show that a long-established work force subject to low dosage had no asbestos-related disease. With this information the industry would be able to put forward the concept of an "acceptable level of risk". However, while the disease data for past years can perhaps be obtained, it is almost impossible to obtain dust level figures from the past because records are not available. (See paras. 56 - 58 below.) More recently the Chairman of ScAP, Dy. Gilson, and Dr. Hans Veill have suggested as an alternative that we make a vorld-vide industry radiograph investigation. (See par2s. 59 - 62 below.) They advise that this could have three results:- (a) It night show that the asbestos workers' health is generally much better than suggested by industry's critics. (b) It could form the basis for a comparability study if carried out at regular intervals (say, every 4 years). UCC 014592 A 0740 o (c) The figures could carry considerable authority since they would be on a world-wide basis. Secondly, the ScAP at Lyon advised that there should be a long-term investigation into lung burden as a measure cf asbestos exposure. Such a study would need sophisticated equipment and highly skilled technical staff. The AIA is therefore trying to collaborate with the SEC Commission in such an undertaking. (See para. 35 below.) Sealing Materials Advisory BaneI faKA?) f Chairman Mr. C.J, Irtir) This Panel has met twice during the period and has been discussing a labelling policy for Sealing Materials products. A report to the Executive Committee will be prepared. Textile 'dvisory Panel (TAP) (Chairman Mr. J.5. Karsh) This Panel is producing three advisory documents (see para. 67) concerned with 'manufacture, application and protective equipment. The EEC Commission - LG III Interests, (internal Market and Industrial Affairs) A long-standing Council Directive (Directive Ho. 67/549/ZEC of 27 June 1967) which deals with the classifying, packaging and labelling of dangerous substances has recently been amended for the sixth time. Among the amendments a new class cf substances "carcinogens" has been added to the Directive's classification list but an appropriate carcinogen label has yet to be agreed. Over 1000 dangerous substances have so far been categorised into 14 different classifications such as "toxic", "inflammable", "explosive", etc.; asbestos however is not yet listed. Ve presume that asbestos fibre (but not asbestos-containing articles) will eventually be classified, possibly as a "cercinogen", but asbestos is clearly not prnving easy to categorise. A related Hcuncil Directive (Directive. ITo. 76/76q/EZT o'- ?7 July WG)~"(which ' steiss froa Directive ICo. Ej) is one which governs the movement of Dangerous Substances between EEC member countries. This Directive is abcut to be amended for the fifth time by a proposed Directive which would allow various types of asbestos to be used in certain ways. *7*03 UCC 014593 -7- As the draft now stands there are different restrictions on the use of crocidolite and on other types of fibre. However, these restrictions allow the main uses of all types of asbestos. Nevertheless, the directive differentiates between crocidolite and other types of fibre and this is proving to be a difficulty since Prance and Germany do not so differentiate in their national legislation. The draft is now at COREPER level and at a recent meeting on 25 June Denmark vetoed the draft as being too lenient towards crocidolite and Germany vetoed it because it was too strict. In the voting,six countries opposed the form of words dealing with crocidolite, while Prance, Germany and Italy were in favour. The next discussions re-open in September. 26. The Scientific Committee on Pood fSCP) (a very prestigious body of distinguished EE scientists) has issued a report which states that there is no proof that there is any danger to health in the use of filters for food and drink or in the use of a/c pipes for drinking water. Unfortunately the report then goes on to suggest that it might be prudent to try and use substitutes. This is not very helpful to us. 27- The report is entitled "Reports of the Scientific Committee for Pood - Ninth Series 1979". Reference 15 BN 92-925-1658-5. Catalogue number CB-NV-79-009-EN-C. It is printed in all the main languages and if a copy is required the AIA EAC offices in Brussels can help you. The EEC Commission - DGV Interests (Social A.ffairs) 28. The Directive on the Protection of Vforkers from Harmful Exposure to Chemical, Physical and Biological Agents at fork (the "Framework11 Directive) was adopted by the Council in June and should be published in the autumn. The Directive nov/ includes a provision 'Allowing national legislation to be more stringent than the EEC's. The industry had bee-n consulted during earlier drafting and the Directive is not in conflict with our interests. Following from this "framework" Directive there will be nine "daughter" directives, cne for each dangerous substance listed and ve are cf course concerned with the one dealing with asbestos. Various working parties and committees on which ve have spokesmen (notably Dr. Bofcock) are involved and our views axe being taken into account. The plan is for this draft asbestos Directive to be submitted to the Council by early September I960. UCC 014594 The Directive will cover all aspects of working with asbestos including:- an allowable asbestos dust concentration; a transitional period (5 years) in which to move from 2 f/cl to 1 f/ml; differentiating or not between fibre types; handling of free fibre; health checks; protective clothing; plant cleaning; waste disposal; measuring methods; monitoring frequency; use of substitutes, etc. D.G.V asked the AIA (through Dr. Robock) to contract for a report on dust measurement methods. The task was given to Hr. W.H. Walton a noted dust expert and his interim report has been sent to the Commission. The final report is to be ready by mid-September I960. Ve understand that in the autumn, DGV are likely to start drafting a new directive which was to have been called "Carcinogens at the Work Place" but which may now be called "Specially Dangerous Substances at the Work Place". This will allow for the control of other dangerous substances besides carcinogens (such as tetrogens and some others which are highly toxic ). The EEC Commission -- DGXII Interests (Research) The DGXII directorate has funds available for research vork on asbestos and we have been asked to suggest topics for research. One which we would like to suggest to the EEC Commission is an investigation by electron microscope into lung burden (see para. 19 above). In the first instance a meeting with certain scientists sponsored by the EEC is needed, then we would hope to broaden the scope world-wide. Eowever, at present we cannot persuade the EEC to move on this matter. The EEC Commission - SKFCInterests (Environment and the Consumer The effect of emissions fron factories into air and water is becoming of more and more interest to the SEC and the AIA is helping them to gather information for the formulation of a directive. The investigation is being handled by T.iT.O. (Toegedast ITederlands Onderzockscenirum) the Dutch research establishment who have sent a questionnaire to AIA Kember Associations in the EEC to be answered by individual firms. Dr. Ioriting, in charge of the project, has recently asked if Greece and Spain (being prospective EEC members) could join in; this has been agreed. UCC 014595 -9- ESC - The European Parliament (E.P.) The -proposed Directive which deals with the movement of asbestos between EEC member countries (see paras. 24 and 25 above) will be passed to the E.P. for its opinion. The natter will be dealt with by Parliamentary Committee Ko.11 (Environment, Public Health & Consumer Protection) and it is important that each Association in the EEC countries makes contact with its own members of the European Parliament who have an understanding of the industrial position and particularly with nembers_o Committee lTo.11. The AIA Brussels office has written to all concerned about this and we emphasise again that the industry point of view should be put to E.P. members before the matter comes up in Parliament. Mr. van der Rest and Mr. Vanherle have already met the Chairman of Committee ITo.11 at Strasbourg; the Committee restarts its meetings on 22 September 1980. EEC - The Economic & Social Committee (S.S.C.) Following from para. 35 the same proposed .directive has already been passed to the ESC for their opinion. Eere the matter is being considered by the Section which deals with "The Environment Public Health and Consumer Protection". A working group has already been formed by this Section and through our Brussels office we have been co-ordinating the appointment of an "expert" (Dr. Gaze) to advise the Group I (industry) members of the Working Group and. of "advisers" (Kr. Bouige and Mr. Vanherle) for individual industry members of the Working Group. Two meetings of the Working Group have been held so far and a preliminary draft opinion has been published which amongst other matters recommends that the use of crocidolite should be limited to a/c pipes larger than 1500 mm diameter. \.Te are strongly opposing this. Inter-Management * s Benort on Asbestos ap.r* the EEC (The Riedl Report") A closely argued report on asbestos and the EEC by Inter-Management (The Riedl Report) has been distributed to members of the Executive Committee and to member associates in the ESC (i.e, to EAC members). This report which has just been received by the Executive Committee supports the advice given in AIA Memorandum 3/79 (dated 31 October 1979) end repeated regularly by the Secretary to the EAC - which is the importance of our National Associations in EEC countries getting to know personally their own countries' representatives involved in the EEC Institutions (Coreper; E.P.; ESC; and the Commission) and keeping them well informed. of our vi ewprint. UCC 014596 - 10 - 39. The Riedl Report also endorses close co-operation with linCE * and CEPIC.+ (AIA has been a member of TOJICE for over two years and has had useful connections with CMFIO through the Brussels office.) The report also recommends that the industry should make a particular effort through national industrialists to inform European H.P.'s about the asbestos industry and that industrialists should do this by going to Strasbourg during sessions of the European Parliament and by meeting members there informally. MATO Scientific Committee 40. Me learned that the Scientific Committee of MATO had become interested in asbestos and had asked T.E.O. (see para. 54 above) to initiate a study with a view to possible research funded by K/TO. Ve made contact with the TNO investigator concerned (Mr. Pornerod) and are now involved in the early stages of planning the exploratory study. Label1in? 41. The AIA "a" logo is now used on all bags of fibre coining from our most important nines. Me have also been in consultation with Rhodesia, Russia and Yugoslavia to see if they also will use the "a" logo. Cyprus, although not a member of the AIA, has agreed to use the logo after present bag stocks are used up. 42. The logo is being used on more and more products and it is to be hoped that the "a" symbol will become known and accepted by governments as veil as by the general public. Consumer lobbies around the world are increasingly insisting that what is cn sale must be properly described and readily recognisable. Ve should keep moving with this tide; whether ve do so or not lies in the hands of our members end it is a matter of regret that a number of these appear to have misinterpreted the position (echoed by a recent asbestos industry report which referred to labelling as "discriminatory"). Labelling has cone to stay and the asbestos industry can be no exception. 45. A draft schedule has been drav.n up incorporating details of the asbestos labelling/logo used in member countries. This will be distributed soon for comment and the incorporation of amendments, suggestions, etc. It will then be sent out in final form end updated as necessary thereafter. * Rnion of Jliropean Corjrrcnity Industrie?. + European Council of Chemical Manufacturers federation UCC 014597 11 44. 45* 46. 4746. Vaste The A1A advisory publication on Taste disposal (RCP 3) vas published in August 1979- (See para. 66 belov.) The 2EC Council Directive Ho. 78/319/EEC of 20 March 1978 on "b'aste Disposal for Dangerous Substances" has now run its two year course and Common Market countries can expect their national authorities to enforce the requirements in the Directive if they have not done so already. There has been questioning in some countries of the dust counts at waste disposal sites and Member Associations should remind company members concerned to take regular dust counts of their waste disposal areas so as to be able (if necessary) to prove their safety to local authorities. Membershin Since the last D.G.'s notes were written, Israel's application to become a member has been agreed by the Governing Council and Nigeria's application will go before the next Governing Council meeting. India has formed a National Association with the intention of joining the AIA and Mexico end Yugoslavia are in the process of discussing the formation of National Associations. Argentina, Rrazil and Korea have been in correspondence on this subject. Conferences TA2C Conference on the Biological Effects of Mineral Fibres held at Lyon on 25/27 September 1979 Close to 300 eminent scientists from 26 countries gathered at Lyon - the conference was organised by the International Agency for Research on Cancer (lARC) in cooperation with the Institut de la Sante et de la Recherche sur le Cancer and the UK Medical Research Council's Pneumoconiosis Unit. This vas intended to be a joint asbestos/HKKP symposium but most of the papers presented were on asbestos because few KKKT research projects had been completed. Nothing very new vas discussed; perhaps this vas due to the fact that most available data refer to exposures- experienced 20-30 years ago. We of course urgently need health data on the effects of current low dust levels. However, the climate of U8 UCC 014598 - 12 - opinion was reasonable although there was a hardening of attitude against amosite; nevertheless, the industry had enough representation to ensure that there was a balanced attitude. Dr. pobock produced the AIA advisory document on a Deference Method for the Measurement of Airborne Fibres a The Colloquium was hosted by the Chambre Syndicale de l'Amiante (CSA) of France (President Hr. Cyril Latty) and covered many aspects of dust measuring techniques and strategy. These included progress end experience with the Reference Method; electron microscopes; ambient air measurements; and automatic counting equipment. The proceedings will be distributed in due course and the next Colloquium will probably be in the Spring of 1981. Other Conferences The Medical Advisory Panel (MAP) advise . the Executive Committee on future conferences which deal with asbestos and health. The MAP also try and ensure that there is an AIA representative present if the conference is of sufficient importance and they further advise if it is considered that papers should be read. The list of conferences is regularly up-dated and circulated to Member Associations. The following are of particular interest 1. "International Symposium on Vater Distribution Systems and Related Health Problems" - Amsterdam 27/29 August 1980. 2. "Fifth International Symposium on Inhaled Particles 1980" (British Occupational Hygiene Society) Cardiff 8/l2 September 1920. (The 2nd AIA Scientific Advisory Panel Meeting will take place at Cardiff on the evening of 9 September I960.) 3. "Epidemiological, Immunological, Genetical Aspects of Asbestosis" Vroclav,Poland, March 1981. (The Executive Committee has decided that the AIA should be represented at this Conference.) 4. "International Symposium on the Prevention of Occupational Cancer" (iLO/kEO/lAEC) Eelsinki, 21/24 April 1981. 3. AIA Biennial Conference, London 26/29 May 1981. 6. Forld Conference cn "Asbestos-Health & Society". (IEDA, Canadian Government A AIA) Montreal - IJSI. (See para. 51 above.) UCC 014c? fuesti onnaire on Loir Lose- Areas The questionnaire to find out where we might make a lov-dose investigation (see paras. 16/17 above) has had a disappointing response. This is probably because the object of the questionnaire was not stated clearly enough and also because there is insufficient knowledge of the dust levels that existed in the oast. The purpose was to give the Executive Committee information on where it might be worthwhile to conduct a research project. In the event most members who were sent the questionnaire cade the decision themselves "no research project here" by not returning the question forms. I thank those who did, but understand the reasoning of those who did not. lie have, however, had seme information as follows:-- 1. .. Ten (lo) plants (out of a possible 1000 -* plants) sent in replies of which two (?) look as if they may have potential but. data needs to accumulate for some years yet. 2. Three (}) companies reported that they have low dose investigations going on in their various plants. They could not say when those projects would be finished. Pad? ographic Investirati on The disappointing response to the AIA questionnaire was discussed with the Chairman of the Scientific Advisory Panel (EcAP), Er. Gilson, and with one of the panel members, Professor Hans belli, who was in the TJ.K. on a visiting professorship. r.oth considered that the AIA with its universal membership including many technically very advanced companies had the capability of providing X-ray health data about its work force which, if properly presented, could bo cost convincing evidence to chow to world scientific opinion. What was mere, this `vident.o war iionediaicly available; time would not be spent in. having to set up an epidetdc-logical study - the problem of course would be in evaluating the radiograph, readings which v.'oro available; but this is purely a mechanical problem.. A074]; UCC 014601 - 15 - The readings could veil show initially that the state of health of the asbestos industry's workforce vorld-vide was ranch better than our critics have suggested; and if readings were taken at suitable intervals thereafter a trend should become evident which would indicate that better conditions were producing healthier work people. Furthermore (as with the TT.K. Coal Eoard findings on a similar scheme concerning pneumoconiosis) the incidence of asbestosis v?ould be seen to be decreasing rapidly in the lower age groups. The Governing Council agreed to a pilot investigatory scheme being launched. This consisted of a short Questionnaire which was sent out to Member Associations to find out whether there were in fact enough plants around the world which had X-ray information on their workers to make the scheme worthwhile. Ve are awaiting the response to this questionnaire; so far 48 plants have replied from 11 countries. The American Conference of Covemgent Industrial Hygienists (ACGIF.') The American Conference of Government Industrial Hygienists has stated that they will recommend in- their annual booklet to be published in September, that standards for asbestos at the work place should be as follows:- Chrysotile 2 f/ml; Amosite 0.5 f/ml; Crocidolite 0.2 f/ml. AIA has written to the secretary of the ACCIE to protest that such a standard would virtually ban the use of Amosite and Crocidolite. The ACGIE Committee on TLYs was put in touch with Dr. Robock some months ago and hopefully he and the DHAP may be able to persuade ACGIE to think again. IT.I.C.C./l.L.O. X-ray Film Classification The HAP have reported that a revised standard set of films has been produced for the ILO 1979 International Classification of Pneumoconiosis. The set can be obtained fron:- ILO Publications, International Labour Office, ' CH-1211 GENEVA 22 (Switzerland) at r cost of Swiss Francs AGO nor set. UCC 014602 <O AIA Advisory Documents The following documents, Recommended Control Procedure (RC?), and Recommended Technical Method (RTM), are available .1 RCP 1 2. RCP 2 3. RCP 3 4- RCP 4 5- RTM 1 The Control of Asbestos Bust (also available in Italian). Asbestos Cement Products (also available in Italian). Asbestos Waste Disposal (also available in Italian) Asbestos Pibre Handling (also available in Italian) Reference Method for Measuring Asbestos Pibres at the Workplace (also available in Italian and being translated into French and Spanish). The following are at various stages approaching the printing stage and are listed in probable order of availability:- .1 On-site a/c tools (to become an insert to RCP2) (being translated into Italian). 2. Bag-opening. 3- Pricticn Materials - manufacture. 4. Priction Materials - maintenance work. 5- Textiles-- manufacture. 6. Textiles - Manufacture of user articles. 7- Protective clothing. 8. Demolition- and Stripping. In addition two leaflets are available 1. The Industry's Viewpoint ConcerningAsbestos. 2. A Digest of Information Concerningthe Association. UCC 014603 - 17 - 69. A background position paper "Asbestos and Health in the Friction Material Industry" is in draft form. Useful Papers and Reports 70. Amongst the very many papers which are published the following show certain positive aspects and have appeared within the last 12 months. Details have been previously circulated to members. 1. "C32 - Report of the Scientific Committee for Food, 9th Series, 1979" (Asbestos -- page 11) (see also paras. 26 & 27 above). 2. "Environment Pollution by Asbestos Fibres". Study by TNO (Butch Research Institute) - Mr, Lanting. 3. "The Health Hazards of Asbestos", M. ITeuberger (Sichere Arbeit, No.3 17-21, 1979)- 4. "Study of wear on asbestos cement products" (institut fur Umweltschutz und Emissionsfragen and the Montanuniversitat in Leoben). 5. "Airborne Levels of Asbestos Fibres in General Occupancy Buildings and an Estimate of Carcinogenic Risk" (James T. Schirripa, Industrial Hygienics Inc., Huntington, N.Y.). 6. "FC Drinking Water Pipes - Incidence and Evaluation of Asbestos Fibres in Drinking Water". (Amianthus Centre. Compact - Information - Pipes, 80-1,May 1980.) 7. "An Investigation of the Use of Asbestos Cement Pipe for Public Water Supply and the Incidence of Gastrointestinal Cancer in Connecticut 1935-1973". (Harrington, Craun, Meigs, Landrigan, Flannery & Woodhull - American Journal of Epidemiology, Vol. 107, No.2). 6. "Asbestos Cement Pipe and Cancer in Connecticut, 1955-1974" (Meigs, Walter, Heston, Millette, Craun, Woodhull Flannery - Journal of Environmental Health, January/February 1980). 9. "Is there a risk to health in using asbestos-cement pipes for the carriage of drinking water?". (S.P. HcCullagh, I960 - Ann. Occup. Hyg. Yol.23, p.169). A 1 UCC 014604 18 - 71. 72. 1J>. 74. 75. 10. "A Rational View of Cancer in Rev Jersey" (Dr. E.B. Demopoulos when Director of the Cancer Institute of New Jersey). 11. "Environmentally Induced Cancer ... Separating Truth from Myth" (Dr. H.B. Demopoulos - talk to Synthetic Organic Chemical Manufacturing Association Inc.). 12. "Cancer in Modem Mortality" (Publication of the U.K. Chemical Industries Association). 13- "The Prevention of Occupational Cancer: an ASTMS Policy Document - A Review by Dr. J. Meir Howard" (TJ.K. Chemical Industries Association Background Paper, 20 June 1980). The following paragraphs cover those countries in which there has been significant activity. Legislation is only reported where some amplification is needed of the consolidated schedule circulated under AIA Memorandum ref. AIA/12/EZC dated June 1980. Details of events in all associate countries as reported by members are shown at the Annex to Governing Council Minutes. Australia A small sub-committee vathin SPAA has been set up to consider ways of countering union pressure against asbestos. Austria A meeting to discuss the problem of fine asbestos dust was held at Vocklabruck at the end of 1979- It was attended by government officials, scientific and factor;1' doctors, scientists and engineers. Details are awaited. Belgium There has been a tightening up of the regulations concerning raw fibre and its handling. Government permission now has to be obtained to import and use raw fibre and plants so doing are inspected for standards. If the standards are adeouate there is no problem. The regulations concerning finished products are reasonable and acceptable to industry. Canada ?f> In December 1979 the Canadian Government sent a deputation of officials, scientists and doctors to Mashingtcn to protest at the UCC 014605 urne c e s sarily stringent rules concerning asbestos and its use 'which were being proposed by the U.B. regulatory authorities. The Canadian deputation discussed the problen with CSBA, HPA and CFSC officials and explained Canadian concern. A tripartite group (government/industry/workerc) from Germany is being invited by the Canadian government for talks and a visit to an asbestos mine. A French group was invited by the Quebec government in December 1979 for a similar purpose and this party included Messrs. Latty and Join and Professor Bignon. Dr. Dunnigan has been appointed Director General of the Institute for the Research and Development of Asbestos (iBDA) in February I960. He had been Director of the asbestos research programme at Sherbrooke University and IFDA's headquarters will be on the university campus. The Chairman of the IKDA Board of Directors is Mr. Michael Prus, Chairman and President of Carey Canadian Inc.. The other sir members of the Board (3 industry and 3 government) are:Marcel Dorais, President of Les Mines d'Aniante Eell Liee; J.PiK. Hutcheson, Chairman of Johns-Manville Canada Inc.; Andre I-Iarier, President and G.II. of Centre de Eecherche Industrielle de Quebec; K.J. Messel, President of Lac d'Aniante du Quebec Lteet Daniel Perlstein, President of Societe Uaticnal de 1'Amiante; Andre" Saumier, Senior Advisor, P-ichardson Securities of Canada. The Institute's main objectives are:- 1. The development of new asbestos-based products. 2. The measurement of the amount of fibre emission into the environment caused by asbestos-based products. 3- Research into the elimination of any such emissions. All aspects of health research will continue to be the responsibility of IOEH whose budget for 1980 is Canadian f 810,700 (funded by fibre producers). Since it started in 1966, IOHE has spent Canadian $ 6,195400 and published 149 papers on matters to do with research into asbestos and health. A Royal Commission tvill sit in Ontario in September 1560 to report on asbestos - the hearings are expected to last for a year and QAKA are preparing to play a part. A 11 6 UCC 014606 - 20 - Denmark SI Ihe list of asbestos-containing products allowed by Danish law is as fol.lows:- 1. Unbonded Packing Katerials until 1 April 1982 2. A/C Products (max. 20/ asbestos by weight) until 1 January 1985 3. Commutators (max. 6Cf/c asbestos by weight) until 1 January 1950 4. Friction Facings (maximum 20/ asbestos by weight) no date limit 5. Bonded Packing Katerials (max. 2C?o asbestos by weight) no date limit 6. Linings (max. 2Ci asbestos by weight) no date limit C2. It-as most important that the asbestos industry should be able to convince vorld scientific opinion that there is an acceptable level of risk for asbestos dust- If we can do this then perhaps the political (not scientific) decision in Denmark to ban asbestos products "unless zero risk from cancer can be proved" might be changed. 83. It is impossible to have a zero risk from anything and most scientists lean to the straight line relationship between a carcinogen and its cancer rate. It is everyone's common experience that some risk in all our activities is a part of living and since asbestos can be no exception to this natural lav, it ought to be possible to convince the Danish authorities that by asking for a zero risk level from asbestos they are: (a) asking the impossible; (b) being discriminatory in doing so. France Ci. A recent decision by the Kinister for Health to ban the use of asbestos filters for.food and drink vrao the subject of a protest by the Chambre Syndicale de 1'Amiante (CSA), our French Association. 'I'his is not a scientific decision since scientists maintain that an asbestos filter.is the most efficient. The EEC's Scientific Committee on Food have stated this (see paras.26/27 t t? UCC 014607 - 21 - above) and the German Government Health Department have recently excepted asbestos filters from a ben v;hich they have put on some other articles (see para. 92.2.2. belov). The French Health Department is also investigating the use of asbestos in certain household articles with a view to limiting their use. Dr. Eulah. Bingham held an informal meeting in Paris on 27 June 1980 vith government representatives, certain doctors including Professor Bignon and Dr. Sebastien and one industry representative, Mr. Bouige. A report of this meeting was circulated to Member Associations (ref. AIA/l/4/8/POL dated 14 July I98O). Dr. Bingham was not very helpful in her comments on the asbestos situation in the U.S.A. The Minister for Health has indicated that the government would be prepared to reduce the exposure level to 1 f/ol if the EEC agreed on this figure. There vas no intention of going to any lower figure. Germany The year has been an eventful one for the asbestos industry, one of the main aspects being the German Government's concern with legislation to improve conditions at the workplace. This has been largely due to Trades Union pressures. Raw Material Regulation 88.1 Discussions have taken place on a draft which modifies the laws governing the handling of all dangerous raw materials in the workplace (in ratification of ILO Convention Uo.139)* These materials are classified as:- (a) highly dangerous; (b) dangerous; (c) less dangerous. Asbestos is classed as dangerous. 88.2 After negotiations involving the political parties, the trades unions and the Ministries of Economic Affairs end of Labour, the current draft regulation concerning asbestos includes the following:-- UCC 014608 (a) various limitations to be imposed on working time if the TLV is above a certain level (still to he laid down - but possibly 1 f/ml); (b) asbestos-containing products to be accompanied by label instructions referring to the Rav;-Tiaterial Regulation; (c) reasons for using asbestos products instead of substitutes to be stated to the local labour authority. Chemical Regulation After much discussion, asbestos does not have to be included under a new modification of this law which would have been very burdensome to the industry. Industrial Catastrophe Regulation Again after much discussion, the asbestos-processing industry will not be included under this Regulation. However the Asbestos Corporation at Korderiham will be included because of it3 large stocks of raw asbestos. Asbestos Cement Law A year ago the Hamburg Senate recommended that asbestos-cement products should no longer be used in public and multi-storied buildings and in underground construction if other materials were available. The Senate nay well try and influence the other ten (lo) Federal States in Germany which would not be a good development. Industrial Safety Regulation (lust) - Second .'nendment 92.1 The Federation of Industrial Accident Insurance and Industrial Safety Corporations (Beruffsgenoschenshaften (EG)) is able to formulate accident prevention regulations which may ultimately be passed as lavra. The JSG recently" passed a second amendment to the Industrial Safety Regulation (Dust). This details certain protective measures to be taken while processing asbestos, which are acceptable to industry. 92.2 In addition the second amendment published a list cf asbestos products which are banned. These were:- UCC 014609 1. Insulating' materials used for accoustic reasons, for heat/cold protection and for use against damp. 2. Filters (except for liquids and the pharmaceutical industry). 3. Paints, putties and adhesives using asbestos as an additive. 4. Mortar and surface fillers using asbestos. 5. Floor covering (this means vinyl underlay for carpets) and road surface materials which incorporate asbestos. 92.3 However, the above can be used without restriction if they can pass a special BG test for dust emission in use (to be less than 0.3 f/ml). Special Meeting The~BG Supervisory Board organised a special meeting on 6/7 Karch I960 to discuss asbestos. There were 700-800 participants and with three individual exceptions the tone of the meeting was positive and helpful, and the press and other media did not distort their subsequent reports. The Hedia Because of increased coverage of asbestos and health matters in the media much effort has been spent by industry to get in touch with editors and TV directors. This has resulted in a more balanced coverage. The Asbestos Institute, Keuss The Asbestos Institute for Occupational and Environmental Safety and Health held a press conference on their first anniversary in January I960. The Institute's Chief Executive, Dr. Klaus Hobock, presided and the scientific technical panel (the Scientific Working Group on Asbestos) with Dr. Bohlig as Chairman also attended. Hie object was to give the true facts about asbestos to selected journalists interested in asbestos. *2c UCC 014610 - 24 - 96. 97. 98. 99 100. 101. 102. Federal Environmentr,I Protection Agency CUnr.-oltb^r.deps-t) This Agency has recently directed all its activities (research programmes etc.) to assessing what danger to the environment is posed by asbestos. Use of f/litre Those German ministries concerned with asbestos are now using the f/litre scale and not f/ml. Netherlands A new regulation has banned asbestos in household articles (irons/toasters). A Tripartite Committee has been set up to advise the government or. asbestos matters. It consists of employers, experts, and trades union members. One of the members from industry is Hr.-'-r. Goedmann. A recent television programme on factories and the environment had shown the Goor Etemit factory as an example of excellence. TT V The Advisory Committee on Asbestos (-ACA) popularly known as the Simpson Committee (after its Chairman) issued its recornendations in December 1979* These have been fully reported elsewhere; among the total of 41 recommendations most of them are, with some reservations, acceptable to U.I'. industry. Two main exceptions are a 0.5 f/ml level for amosite and a ban on crocidolite. The ACA recommendations are being discussed at present and it appears that final decisions and hence legislation will be delayed for seme considerable time. yet. A (draft) Cede of Practice and Guidance Note under the Health and Safety at V.ork Act is about to be issued. It covers work with asbestos insulation and with asbestos coatings and deals with personal protection, plant and process control and asbestos waste and has industry's full supuort. 4 UCC 014611 Certain regulatory agencies in the U.S., notably the Occupational Safety and Health Administration (OSHA); the Environmental Protection Agency (EPA) and the Consumer Product Safety Commission (CPSC) have shown by their combined actions that they are aiming for legislation concerning asbestos which would effectively stop its use. AIA/NA have successfully queried EPA's water quality criteria document resulting in this being delayed indefinitely. In addition OSHA is considering AIA/lTA's suggestion of a model standard for the regulation of the construction industry. But in other areas AIA/NA has not been able to persuade government officials to adopt a practical and realistic approach to the problem and this difficulty has been aggravated by the attitude of organised labour and of public interest groups. Thus AIA/lTA decided to retain a lav; firm to advise them on:- (a) Pule-maleing processes. (b) Possible future legislation. The Advance Notices of Proposed Rulemaking (ANPR) which were issued by EPA and CPSC in 1579 were strongly argued against by AIA/lTA within the deadline set for response (18 February I960;. The AIA/lTA document sent to EPA consisted of 55 pages and that to CPSC was similar. The nub of the arguments in both cases was that unreasonable risk had to be proved before government could pro-nose any regulation under the Toxic Substances Control Act (T3CA). Members may be interested to know that the lav; firm retained by AIA/NA had been earlier retained by the U.S. Chemical Industry who were contesting an OSEA-imposed workplace standard for benzene ten times more stringent than was considered necessary. This case has just been won by the Chemical Industry and it is now up to OSHA. to -prove that the hitherto accepted benzene standard is harmful and to orove at what level any new OSHA standard should be set. This decision is bound to have a fax-reaching impact on all U.S. Government programmes to control carcinogens and, for example, will have a bearing on OSKA's stated intention of reducing the UCC 014612 present 2 fibre/ml workplace standard for asbestos. If the new precedent is followed, OSBA will have to prove: (a) that 2 f/ml is unhealthy; (b) v/hat is a healthy lover level. OSEA has announced that action is to be started on asbestos rule-making during I960. The standard to be proposed may follow recent recommendations to OSSA which were made by a research institute (the Research Triangle Institute) (PTl) which suggested that it was possible to manufacture at the following exposure levels:- Host products (except dry woven textiles) 0.2 f/ml Automotive after-market 0.2 f/ml Shipbuilding 0.5 f/ml Secondary fabricators 0.5 f/ml Construction 0.5 f/nl (except for removal, maintenance and demolition) Ship repair 2.0 f/ml. Whether OSHA accepts these levels as practical for rule-making remains to be seen. The time-table for expected OSEA legislatory initiatives is roughly as follows Advance ITotice of Proposed Rule-leaking ( AHPR) - July/August I960 Proposed Rule - Sept./October I960 Public Hearings - Feb./March 1981 (?) Final Rule - Eay/June 1981 The ERA has announced that a limitation or ban on non-essential commercial and industrial uses of asbestos would be considered but such action depended on showing an unreasonable risk with asbestos, the reliability of the substitute and the economic consequences of banning. UFA recognises that in order to minimise the impact on industry the timing of any effective dates could range from 198? to 1995 and possibly later, resulting from any judicial appeal. A UCC 014613 - 21 - 111 112. 113. The tine-table for expected EPA legislatory initiatives following their AKP5 is approximately: AK??i vas published Proposed Rule Public Hearings October 1979 December 1930 (?) (?) 1931 Pinal Rule (?) 1932 AIA/I'A*s lavyers need to assemble as much information as possible in order to prepare their case and a list of AlA/SA's requirements toward this end is shown in summary form as an Annex to this letter. The information asked for has been sent, or is being prepared to be sent, by many Member Associations around the world direct to ATA/1TA. However, if you have not already been contacted by this office .to forward information to AIA/NA and if you feel that yon may have information which could be useful to them, please send the data directly to AIA/NA (plus copy to this office, please). aia/aiAt August 1980 Attachment: "Summary of information Heeds for United States Regulatory Proceedings". 4 UCC 014614 Attachment to AIA NOTES EOR ASSOCIATION'S JULY 1980 SUMMARY OF INFORMATION NEEDS FOR UNITED STATES REGULATORY PROCEEDINGS Historical data indicating whether or not the amount of asbestos in the general environment increases to any significant extent from man's use of asbestos. Studies of the eventual fate of once-released asbestos fibers. Studies of the accuracy and validity of measurements made by the membrane filter method, especially at levels below .5 fibers/cc. Critiques of present sampling methods, reviews of their relative strength or weaknesses, evaluations of conver sions among various measurement techniques, and deter minations of the relative sensitivity of past and present measurement methods. Medical evidence from individual asbestos companies, especially if unpublished, of the health effects observed in their employees. Medical critiques of the dose/response relationship of asbestos and health, variances of effects among fiber types, the effect of smoking, and risk assessments for asbestos at low levels of exposure. Documented historical information of the levels of asbestos exposure among asbestos employees, especially at plants where epidemiology studies have been conducted. Current asbestos exposure levels at all stages of the mining, milling and manufacturing process and during product installation and use. Descriptions of historical efforts to reduce worker exposure, indicating costs incurred, methods used, degree of success in achieving reductions, and the limitations on any further reductions. Analyses of the economic availability, efficiency and medical effect trade-offs inherent in various suggested substitutes for asbestos or asbestos-containing products. UCC 014615