Document 99xDVmZGDQxvEw0YrN2b0M1MR

FILE NAME Brakes BRK DATE 2003 Oct 1 DOC BRK129 DOCUMENT DESCRIPTION Letter to EPA from Dr. Leigh University of Sydney The University of Sydney NSW 2006 AUSTRALIA Dr James Leigh PhD MD MSc MA BLegS FAFOM FAFPHM Senior Lecturer Director Director Centre for Occupational and Environmental Health School of Public Health Faculty of Medicine Telephone +61 2 9416 4577 Facsimile +61 2 94164577 Email leigh @bigpond com 1 October 2003 Information Quality Guidelines Staff Mail Code 28220T U.S EPA 1200 Pennsylvania Ave N.W Washington DC 20460 USA Dear Madam 1986 EPA Gold Book " Guidance for preventing asbestos related disease among auto mechanics for correction http://www.epa.gov/oei/qualityguidelines/af correction sub.htm 12 Request of the Australian Mesothelioma Register from 1988-2001 while working with the Australian Federal I was Coordinator Health and Safety Commission as Head Epidemiology Unit 1988-1998 and Head , Research Government National Occupational other publications from the Register during this Unit 1998-2001 I was responsible for the production of annual reports and many period and to date since retiring from the government to take up a university position I am now Director Centre for Occupational and Environmental Health , School of Public Health University of Sydney that In revision of the Gold Book the following information should be taken into account as in my view this evidence any , have an increased mesothelioma risk due to asbestos exposure at work demonstrates automechanics clearly The Australian Mesothelioma Register collects data on all mesothelioma cases in Australia The register has been in operation since 1/1/1980 Only histologically confirmed cases are accepted Up to 31/12/1985 pathology panel diagnosis was used and a and environmental history obtained by interview of patient or close relative carried out by trained interviewer doefttaeinlend uorccsuepaFtrioonmal1986 onwards history is obtained by detailed history in % cases and remainder by mail questionnaire with up to four follow up letters Notifications prior to 1982 and post 2001 are less reliable due to newness of program pre 1982 and new privacy legislation 2001 In the cases 1986-2001 1986-2001 , 78 cases out of 3956 responding to occupational history questionnaire or providing hInis4t3oroyf gthaevseeabrake history of asbestos exposure in brake lining repair or manufacture 73 were brake lining repair 5 manufacture lining repair was the only source of asbestos exposure There were an additional 8 vehicle mechanics where this job was the only source of asbestos exposure in 718 cases with available history in the period 1/1/1980 - 31/12/1985 There were 8 cases in the period 2002- 30/6/2003 out of 488 notified with asbestos exposure involving brake lining repair or manufacture In 3 of these this was the only source of asbestos exposure This rate would be increased by allowing for non response rate for history of about % . The rate in brake mechanics only would be greater after allowing for vehicle mechanics not doing any brake lining work a small fraction in Australia Alternatively an approximate lifetime risk for vehicle mechanics exposed in the 1950-1960s can be estimated as follows Average population for vehicle mechanic = mean of 1933 and 1997-98 = 15326 + 82694 2 = 49010 Average annual incidence 1986-2001 = 49010 x 16 = 54.8 per million person Lifetime risk approximately = 70 x 54.8 per million = 0.38 This is approximately 55 times the background lifetime risk of 70 per million 0.007 It should be noted that this is a different analysis to the case referent studies included in the meta analysis of Wong Reg Pharm Tox 170-177 The comparison in these studies estimates odds ratio relative risk approximation for ever employed as auto mechanic compared to never employed as auto mechanic and effectively compares risk as auto mechanic to risk averaged over all other occupations which is not the same as risk compared to background environmental exposure For comparison with such studies the cohort equivalent would be approximately 49010 x16 x 70 / average lifetime risk for - . Australialal occupations} = 0.65 % / 0.22 = 2.96 which is still clearly greater than unity If restricted to auto mechanic work where this was the only asbestos exposure the corresponding figure would be 49010x16 x 70 x100 % 0.22 0.38 0.22 = 1.7 which is also greater than unity Unfortunately none of the vehicle mechanics has had lung fibre content analysed To my knowledge no crocidolite or amosite was used in automotive friction products used in Australia It is possible that some tremolite contamination was present in products containing Canadian or Australian chrysotile REFERENCES Australian Mesothelioma Register Report 2002. NOHSC Canberra . J Leigh , P Davidson L Hendrie D Berry Malignant mesothelioma in Australia 1945-2000 Am J Ind Med 188-201 J.Leigh T Driscoll Malignant Mesothelioma in Australia 1945-2002 Int J Occ Env Health 206-217 2003 Yours faithfully Dr James Leigh