Document 9L4Z0O6d9VK7yzBGE7GrL3gNq

FILE NAME Quebec Asbestos Mining Association QAMA DATE 1979 Aug DOC QAMA160 DOCUMENT DESCRIPTION QAMA Bulletin Vol 3 No. 4 The asbestos industry and Bill 17 On Thursday September 6 1979 the Association des mines d'amiante du Qu^'becpresented a brief to the Permanent Labour and Manpower Commission of Qu^'bec's National Assembly in which it expressed the viewpoint of the asbestos industry on Bill 17 dealing with occupational health and safety The publication of this issue of the Bulletin was delayed by one week so as to allow the text of the AMAQ document to be published in extenso immediate- ly after its presentation to the Commission The Association des mines d'amiante du Qu^'becwhich has agreed with the objectives put forward in the White Paper on occupational health and safety acknowledges the justification of overall legislation on the matter and the relevance of reform aimed at replacing the numerous cur- rent laws and regulations and the fragmentation of administrative responsibilities with a more coherent system and a unified set of norms We do not dispute the merits of a policy aimed at elim- inating the causes of occupational accidents and work lated diseases but rather feel that such initiative on the part of public authorities is timely all the while ing in a positive way to collective awareness of lems inherent in occupational health and hygiene contribut- the prob- The member companies of our Association subscribe all the more readily to the general direction of the policy expressed in the White Paper as they all have action programs which in the final analysis adhere to the objectives of the White Paper The experience of the asbestos industry These programs deal with medical and scientific re- search occupational medicine in direct contact with the work environment development advanced technology with a direct impact on prevention of occupational risks and on hygiene at work the modernization of facilities and equipment intended for air purification and the improvement of the environment and the quality of life Substantial human and material resources are involved in these programs an institute of occupational and environmental health entirely financed by the industry and which makes use of the most noted specialists in the world health clinics at Thetford Mines and at Asbestos with their own doctors and health professionals and rate equipment consultant environmental consultants high- ly active permanent committees in the following fields environment occupational health and hygiene safety and acci- dent prevention It is mainly in light of this effort and experience that we are intervening in the current discussion on Bill 17 We believe that it contains elements which if maintained are of the type to hinder in actual fact the attainment of the fundamental objective of the Bill which is the health and safety of workers Therefore our intervention is aimed at showing which elements in our opinion should in all necessity be revised and it will deal with the following Health clinics and services health and safety committees inspection the exercise of the right to refusal the prevention representative medical diagnosis 1. Health clinics and services Regarding occupational health services we cannot understand why the authors of the Bill chose such a straight and narrow path By favouring abusive bureaucracy and functionarism in the organizational structure and operation of health services such a path thwarts more than it actually establishes the principle of the taking in hand by the milieu of health and hygiene at work which in fact was a basic premise in the orientation of the White Paper Above and beyond the fact we feel that health services for workers are part of the responsibilities inherent in the management of a company and that we would find it inadmissible for the legislator to use as a pretext the promotion La Bulleti|n Insidiously of occupational health and safety in order to withdraw the rights which are part and parcel of manage- ment in the economic and political system we live we limiting feel that as far as health services are concerned the Bill is unreasonably restrictive and It is obvious that existing programs and services were not taken into account and it also appears that the authors confused the role of a doctor with that of an arbitrator or conciliator mining From the viewpoint of the competence of their profes- sionals the quality of their services and equipment the Asbestos and Thetford Mines occupational medicine clinics for example are more than equal to what exists in this field namely in public public or As a matter of fact their thorough community centres knowledge of the milieu and all aspects allows them to be in a position to better serve with all the required attention workers who could not receive such care from other institutions or fessionals unfamiliar with the asbestos pro- working environ- ment and who have no practical experience of the problems and solutions which are particular to this environment irresponsibili- From this point of view the exclusion of health clinicS established in the private sector borders on ty because it would eliminate nedlesly and gratuitously . In the case of occupational medicine clinics extremely precious accumulated experience and competence and services which have proven their professionalism and ef- ficiency Always taking into account its objective the Bill should to the contrary encourage the maintaining and development of such clinics and thus create between the public and vate sectors healthy and stimulating competition which cprainonly be beneficial to workers and favour the implementa- tion of sound occupational medicine in Qu^'bec Industry it would be deplorable lhal the legislator block their scope by subjecting this industry to a general levelling process which would discourage all initiative The occupational doctor As for the choice of occupational doctors we feel that the only enteria for in companies tor must be his hiring an occupational doc- professional competence and aptitude to best meet the duties to be performed Recruiting should be carried out according to rigorous standards to obtain the highest degree of professionalism In carrying out his medical profession the occupational doctor in a company should not nor ever be subjected to State authority company authority or worker must abide by the dictates of his professional corpauotrhaotriiotny but This does not however prevent that mechanisms be developed so that doctors just like nurses hygienists toxicologists and epidemiologists work in close cooperation Sion which However we feel it unacceptable that the choice of tor be submitted to a vote by a a doc- parity committee in the employer or union sympathies obvious or lable to weigh more heavily than professional assumed are competence Health programs As for the development of health and safety programs companies can generally better detine and determine their own needs concerning medical examinations and the type of services required to obtain the optimum performance in preventing and solving health and safety problems Here again we observe that the authors of the Bill have followed a straight and narrow path which is rigid and restrictive instead of fostering an open policy encouraging develop- ment in conjunction with the appropriate public organiza- tions of the best possible programs designed and structured in accordance with the very needs of each industry In the case of health and safely programs in the asbestos sible for the smooth management of all activities in his company including health services it being understood that the independence the appointed doctor competence competence and integrity of conform to established must norms We therefore request that the Bill be revised in this re- gard to take into account the imperatives inherent in viding health services in an pro- allow for free industry such as ours and to choice in the hiring of health professionals Whether time occupational doctors or consultant tors are involved we feel that we are for the right to call upon the best justified in asking without elements of the profession or publicasneyctcoornsideration whether they belong to the private should agree to reflect upon the very constitution and defi- comites voluntary nition of these committees by making them voluntary and responsibili- consultative by more equitably equitably the responsibili- lies of each and above all by avoiding that they become the ofextnsio employer union disputes on the respective rights and obligations of workers and employers 3. Inspection At another level the Association des mines d'amiante health Quebec Quebec questions the pertinence of all unifying the Again safety inspection services as the Bill proposes , and authors appear to have given free rein to a asbestos in which the specifics of an industry such as the asbestos mining industry are cast aside has special character which particularities is Indedvery own mining to sector responsible complexities adherence safetynorms seeing to safety aplication in and general way not ensuring to suitably carry outlhawis s job regulations if familiar did not have way training the details possible full andcircumstances of mining whether in the pit or in the processing plant There is no doubt in our minds that supervision genral the health and safety conditions of mining workers in general general and asbestos mining workers in ef ectively particular can effectively ensured by specialissptescialists working with government government department directly in contactcontact with the mining actaicvittiyvity the l'inspection this regard the Service de l'inspection des minemsines which enforces l'inspection application of the Mining Act the appears to be the ideal body to carry out in all mining the new plan even under even plan inspection of the mines mines should be the responsiblity of a government richesses body other than Minist^- Minist^- des richesses naturelles which wouldwould rather ap ear odd , the task should necessarily be pro- mining assigned obvious obvious with fessionals well familiar with mining operationsoperations for reasons of efficiency and the smooth operation of the iinn- - specting process 4. The exercise of the right to refusal Regarding the rights and obligations of the worker we recognize the right of a worker to refuse refuse to carry out job recognizerecognize reasonable will job being that performing physi- job motives to believe expose him to risks for his health , safety or physi- or could have the effect of exposing another similar risk person concept of good or bad faith to which this chapter of the Bill refers may lead to abuses misunderstandings misunderstandings and useless litigation and regarding the rights does of a not have worker to a place place refuse in to the articles carry out a job We therefore feel that the concept of reasonable motives stated in in the Bill must be the only only one kept as it ensures more efficiently the objective application of the rights of the and and employe 5. The prevention representative The section of the Bill dealing with the appointment of prevention representatives leads to confusion as written In one instance it is stipulated that workers one prevention repre- more people to carry out the duties or prevention repre- people prevntio another reference is made lo one preven-preven- sentativesrepresentative The time a prevention representative can employer's devote duties at his employer's expense could be substantial his addition he can take without salary loss as much leave of absence as needed to participateparticipate in training programs the content and length of which are approved should should Com- mission Consequently simple common sense should the legislator to limit prevention representation feel that one prevention representative per is , except perhaps in the larger enough companies in which establish determine set- the Bill can establish or determine the method ting the number of representatives in accordance with the size of the enterprise and the number of employees 2. Health and safety committees employee On the other hard if there is a field in which more than any other cooperation to be useful and efficient must be accepted freely by the partles and completely absent of power plays it is surely the health and safety field 2 Such committees inevitably risk deviating from their pri- mary objectives if they truly do not convey the will of ployers and employees to em- cooperate in finding solutions to problems of health and safety The Bill in this regard paves the confrontations even way for all types of objectives of health anbdarsagfaemtiyng to the detriment of the true thisInasmuch as the legislator above all wants to see that necessary cooperation becomes real and feasible he 6. Medical diagnosis important especially Concerning transitory provisions 279 we have noted an extremely extremely important omission article propsed modification aims at replreplacing acing a para- The Bill 52 1975 by a new text which has the effect of of the concept of positive diagnosis in the eliminating only and asbestosis disability resulting from silicosis by det rmined mentioning silicosis and asbestosis medically determined d through diagnosis Association des mines d'da'ammiaannttee du Qu^'becopposes undermining this change which would have the effect of undermining thethe concept had the concept of positive diagnosis opportunity when hearings on Bill 52 were term held a few years ago of showing the inadequacy of the medical diagnosis without any other precision and misleading interpretations it led to misleading time, proved to the satisfaction legisla- interpetaions of the positive tor the necessity of introducing the concept of the only way to ensure that diagnoses based diagnosis are on medical and scientific data free from any partiality partiality Our request request does not have any goal in prevent other matters to prevent return to arbitrary and subjective rule in matters med- crucial ical thus compromising on a crucial point the ical diagnosis legislation just and of on health and safety |Bulletin| Asbestos finished sheets a combination of elegance and solidity of safety and economy Asbestos applications are so numerous and varied that it would be difficult to draw up an exhaustive list especially as these applications are evolving according to the changing pace of consumer needs and tastes Several products containing asbestos in order to make use of the unique characteristics of the fibre are therefore constantly being developed to satisfy the new requirements of the market Thus during the last few years new use was developed for fibrocement in the construction field namely asbestos finished sheets a decorative material which lends itself particularly well to exterior and interior architectural facings Sophisticated products Finished sheets can be found in curtain walls edging balcony surfacing soffile ceillings tympanum or partition walls in various types hotels of buildings multiple apartment dwellings hotels hospitals office buildings schools community cen- tres etc Contrary to traditional corrugated or flat sheets used primarily for functional purposes for the cladding of Industrial buildings coloured or textured asbestos ment finished sheets are more spe- cialized and sophisticated products which are used for cladding com- mercial public institutional or residential buildings whose aes- thetic appearance is a major con- cern of architects Manufacturing process Made of a mixture of Portland type cement and asbestos fibres 12 to 15 content generally grade 4 the finished sheets like all fibrocement products do not present any risk to the health of users due to the fact that the fibre is com- pletely interlocked in the mixture Coloured sheets are formed by a compression process into flat panels which are then polished and covered by a pastel or bright coloured coating The finished product has a smooth semi and unformly coloured surface The pa- nels are produced in various thick- nesses and sizes Textured sheets have a rough- finish surface and are generally white grey sand or earth colour- ed Their manufacturing process varies according to producers The mixture can be dyed before being compressed and then molded into the desired texture or shape or again dyed and molded without going through the compression stage In certain cases the texture is obtained through sanding In other cases the mixture is not dyed so that the finished sheet has the natural grey colour of asbes- cement Characteristics and advantages The large variety of available shades for coloured sheets and the numerous finishes which can be - t na There is a great variety of on the construction of a mansard roof with coloured cemnt sheets sheets for finished sheels Left coloured are used Right the front and soffit ceiling of an elegant marquee are covered i et anaes i Left an aged stone effect has been given to a textured asbestos sheet Right The ceiling and walls of a catctoria have been covered with coloured sheets the are decorative as well as durable and easy to clean given to textured sheets make the products very appealing to archi- tects who wish to create new and original effects in exterior and interior facings of the buildings they design and who must at the same time take into account safety standards which are becoming more and more severe and respect the concerns of contractors about sav- ings and costs The asbestos finished sheet does meet all these requirements Other than its aesthetic qualities it has characteristics which often give it advantages over certain competitive materials such as concrete brick etc Thus all the while providing excellent resistance to pressure due to the reinforcement properties of the asbestos fibre it is relatively light much more so than concrete for example This allows builders to use lighter structures which are more economical and simpler installation methods which are faster and less expensive In addition like all products combining asbestos and cement the finished sheet is noncombustible thus providing a protection guarantee against fire spreading and smoke emissions It also can withstand humidity and sharp drops or rises in temperature and its low lineary heat expansion coefficient gives it considerable dimensional stability Interesting potential Coloured sheets are quite popular in Western Europe where all their production centered EterBelgique manufactures among other things high quality coloured sheets marketed in Europe under the trade name Glazal However the use of coloured sheets in North America is still not very widespread as architects and builders are not familiar with the range of possibilities the product can offer Textured sheets are better known on this continent Two large pro- ducers of fibrocement products Johns Manville in the United States and Atlas Turner in Canada are already involved in the production of textured sheets which are marketed under various trade names In addition the natural finish and rugged appearance of the sheets better correspond to North American lastes at least as far as exterior facings are concerned Japan and other highly industrialized countries represent interesting potential markets for asbes- cement finished sheets which are high quality sophisticated prod- ucts With the increase in cost of traditional materials and the quest for new shapes and lines in modern architecture finished sheets are destined to take a greater and greater share of the decorative material market Indeed they possess a combination of qualities which is almost unequalled by other products all the while being economically competitive 4 Statement of the international asbestos industry For some years now the effect of asbestos on human health has been the subject of steadily increasing controversy While there has been investigaon into this subject the state of knowledge is far from complete At the same time the discussion is becoming increasingly emotional and this is conducive neither to the adoption of good and reasonable regulation nor to providing a for the improvement of knowledge In these circumstances , the of those concerned and in particular will continue to operate with all the workers and their representative organisations the medical and scientific professions national and international authorities in order to achieve the following # defining and establishing measures for worker protection encouraging and undertaking all the requisite technical scientific and medical studies for gaining improved knowledge of the pathology of asbestos obscure disease a large number of features of which still remain * comparing and discussing together the conclusions that can be drawn from the present state of knowledge In this context the asbestos industry represented by the Asbestos International Association wishes to state its position as follows 1. The health hazards associated with asbestos are due 10 the inhalation of fine asbestos dust It is known that excessive exposure to uncontrolled concentrations of asbestos dust can result in the onset of asbestosis cancers of the lung and mesothelioma 2. These occupational diseases normally show up only afler a period of 15 to 40 or more years after the exposure This indicates that the cases presently occurring are the result of working conditions that were very different from those encountered today the dust levels at that time were 100 or even 1000 times higher than at present It also follows that the cases of asbestos disease which will occur in the near future will also have had their origins in past conditions 3. A dust level not exceeding 2 tibres per cc is considered by the industry as the basic necessary requirement and the industry considers that regulation to achieve this is both necessary and useful The overall objective is to reduce the fibrous dust content of the air as far below two fibres per cc as is possible and wherever possible at the earliest opportunity 4. The industry considers that the dust level of work places should be regularly monitored The workers concerned and their representatives should be kept advised of the results as are factory doctors and official health inspectors 5. Uses of asbestos in which adequate dust control cannot be achieved such as spraying should be abandoned 6. industry is continuously striving to improve the quality of its products and is actively investigating the de- and of alternative materials In this connection however is emphasised that such ma- terials must meet three basic requirements a they must present less hazard to health than the asbestos product b they must offer equivalent technical properties notably in the way of fire protection and in terms of thermal and chemical resistance and mechanical strength c they must be economically satisfactory 7. The policy of the industry is to give adequate information to users of containing products in order to ensure that these are used safely 8. Scientific data on the asbestos and health problem are still insufficient The industry considers that new research must be urgently undertaken and is prepared to ordinate help in organising this and to the work in different countries In such studies which require close international colaboration between researchers priority should be given to the following the . epidemiology of asbestosis lung cancer and mesothelioma = the effects of tobacco and other carchiogenic factors the possible relationship between ingested asbestos and di- sease 9. In the present state of scientific knowledge there is no evidence that the proper use of asbestos products involves any health risks to the public at large Standardization of dust measuring methods The Panel The members of the Dust Mea- surement Advisory Panel and authors of the document are Dr. Klaus Ro- The Dust Measurement Advisory by the various laboratories 18 such bock of the Asbestos Institute for Panel of the Asbestos International Association AIA which includes experts from several countries has finalized development of a referen- ce method for the determination of airborne asbestos fibre concentra- tions at workplaces by light micros- that it leads to almost as many methods as there are laboratories This is due in part to variables which occur at various steps in the process collection of air samples preparation of the slide counting criteria etc. Ocupational Germany Occupational and Environmental Safety and Health Germany Chairman of the Panel Daniel Bouige of the Laboratoire d'hygi^ne et de contr^ledes fibres min^'ralesFrance Dr Gerald R Chase of JohnsManville Sales Corporation United copy To this end the members of the States Geoffrey Pickford of the Research and Engineering Centre of Panel met during the last week of James Hardie & Coy Pty Ltd Aus- June at Bromont Qu^'bec where they were the guests of the Association des mines d'amiante du Qu^'bec The meeting the fourth since formation of the Panel also provid- tralia Dr Harrison B Rhodes of the Metal Division of Union Carbide Corporation United States Anthony L Rickards of the Asbestos Fibre Laboratory of Turner & Newall ed an opportunity for the members to visit at Asbestos the Johns- Ltd. United Kingdom Ulricht Teichert of the Asbestos Institute for Manville Canada facilities and at Mont Hilaire the laboratory of the Occupational Safety and Health Centre of McGill University headed Occupational and Environmental Safety and Health Germany acting Secretary of the Panel and Marc Trudeau Technical Advisor of the by Dr. G.W. Gibbs Association des mines d'amiante du 18 months of work Qu^'bec Mr R Sykes of the Asbestos Research Council United King- The reference method adopted at Bromont establishes a standardized procedure to be used to measure fibre concentrations through mem- An illustration of air sample collection at the workplace dom formerly member of the Panel also played an active role in the development of the reference method brane filtering It is the result of work carried out over the last year half by the members of the Panel who applied themselves during this period in evaluating the techniques and equipment in use throughout the world and in selecting the Standard procedure Aware of the necessity of remedying such a situation the Dust Measurement Advisory Panel of the The Dust Measurement Advisory Panel created by the AIA in 1977 meets at least three times a year Its main assignment is to standardize the methods used to measure asbestos dust best elements in order to arrive al a unique and uniform method which would facilitate particularly for epidemiological purposes measurement comparisons on an interna- tional scale It was at the first internationaf symposium an dust measurement held in August 1977 at Warmensteinach West Germany that specialists emphasized the lack of uniformity in the use and understanding of the membrane filter method In fact the interpretation of the method AIA therefore undertook development of a reference method allowing the procedure to be internationalized A first draft was presented in Washington in October 1978 during the second symposium on dust measurement It was favourably received by the interested scientific and government organizations whose numerous comments often very pertinent led the Panel to make certain changes and to improve the project before giving it its final form at the Bromont meeting Current projects The reference method for the determination of airborne asbestos fibre concentrations in workplaces is only the first step in the program which the Panel has set for itself Members have already undertaken two new projects with regard respectively to the measurement of asbestos dust emitted into the environment and to the measurement of dust emitted from chimneys in the asbestos industry Adoption of an international symbol for labelling of asbestos bags Canadian asbestos fibre producers have all accepted a proposal submitted by the Asbestos International Association AIA which recommended that a graphic symbol be added to the caution warnings on asbestos fibre bags shipped from their respective processing plants The chosen symbol is currently in use in the United Kingdom and certain other countries and highlights the letter a meaning both asbestos and attention The logo is composed of a stylized a on a black background surrounded by a red border thereby making the symbol very distinctive avoid creating dust and that breathing asbestos dust could be detrimental to health During the last two years several producers took it upon themselves to make the text more explicit and in certain cases have even included Labelling For several years now producers have been labelling bags with a written warning in accordance with requirements of organizations responsible for ensuring the health of workers such OSHA Occupational Safety and Health Administration of the United States The text cautions eventual users that the bags contain asbestos fibres that they should a warning to the effect that smoking considerably increases the risks to health According to the new labelling policy adopted by Canadian produc- ers each company will continue to have its own warning printed on the bags but the a logo will be used by all International symbol It is anticipated that the a will eventually become the international caution symbol in the asbestos industry In fact in the manufacturing sector it is already used on the packaging of containing products in Australia Ireland New Zealand and the United Kingdom and will shortly be applied in Belgium Canada Denmark Finland Germa- ny Holland Luxemburg and South Africa On the other hand most fibre producing members of the AIA will follow the example of Canadian producers so that the logo will be used in all the major asbestos producing and consuming countries Bulleti_ na This BULLETIN is published by l'Association des mines d'amiante du Qu^'bec 1130 Sherbrooke Street West Suite 410 Montr^'al H3A 2M8 The Post Office Department in Ottawa has authorized postage paid in cash and forwarding of the publication by third class mail Canada i*Post Postage card Postes Canada pow Bulk third class 264 En nombre troisi^me classe Montr^'alP.Q. ay] 20AD