Document Nn7y8VdYbqzrRLGrVeVavpkg

-. U i. A A k (* J.JUJ + XlmSt+J (Limited by Guarantee) X X A V/ 68 GLOUCESTER PLACE, LONDON WiH 3HL MEMORANDUM TO: All Member Associations FROM: Director-General AIA/1/7/P0L 5 March 1980 Comments by AIA on the ACA's Final Report Attached is a copy of the AIA's comments on the ACA Report. Would you please ensure that members of your Association who are interested, and particularly your member of the Governing Council and any Advisory Panel members in your country, are sent a copy. Sir Neville Stack cc Members of Executive Committee CAPCO JEN 0012484 (Limited by Guarantee) GLOUCESTER PLACE, LONDON WiH 3HL, ENGLAND Miss S. C. Newton, Health and Safety Executive, 25 Chapel Street, London NW1 5DT. Telephone: 01-486 3598/p Telegrams: InUg London Tele*: 398618 1NTA G AIA/1/7/P0L 4 March 1980 FINAL REPORT OF THE ADVISORY COMMITTEE ON ASBESTOS Comment by the Asbestos International Association The AIA has considered the Report of the Advisory Committee on Asbestos and has distributed over 100 copies throughout the world to its Members. Some of our Members have strong views on specific matters dealt with in the Report. As an Association, however, we feel that it would be inappropriate to comment on all of these aspects in detail. We have therefore concluded that it would be better for individual countries to reply on matters specific to themselves and we have encouraged them to do this. However, the AIA considers that it should bring to your attention some issues of principle as well as views broadly held among AIA Members. General Comments: In accordance with the AIA's statement on asbestos and health questions issued originally in October 1978 (December 1979 reprint enclosed), the asbestos industry takes the view that the controlled use of asbestos at work and the proper use of asbestos-containing products in daily life do not represent significant health hazards. Practical experience with low-dose exposure in different countries appears to support this position, and we have some confidence that ongoing research and epidemiological studies will provide further confirmation. As the ACA Report makes clear, we must appreciate that present day diseases are the consequences of uncontrolled past exposure to asbestos dust and that nearly all existing studies are based on these past conditions. Today's levels of exposure, however, are lower by up to a factor of 1000 depending on the kind of industrial process and application. In the light of present knowledge of the health hazards associated with the inhalation of asbestos dust and the availability nowadays of considerably improved methods of control, the AIA feels strongly that it is more appropriate to strive for the controlled use of asbestos' rather than opt for precipitate substitution or even an unconditional ban. CAP CO JEN 0012485 <i March 1980 This philosophy has also been expressed by the ACA in Volume 1, paragraph 141, of the Report. There it is stated as a general principle that `control 'of 'any 'useful but hazardous material is preferable to the ultimate sanction of prohibition. The Report goes on to say that "prohibition of a particular substance may directly result in an increase in health or safety risks, for example from fire, which the use of that substance currently prevents or reduces. It also ignores the implications of statutorily enforcing substitution by materials or substances which at present appear to be suitable but may at a later date be found to constitute a risk to health". As to substitution the Report takes the view in paragraph 146 that "where a substance such-as asbestos has no clearly defined threshold concentration below which the health risk is non-existent there are obvious advantages in replacing it with an alternative material, provided that alternative is significantly less hazardous". In paragraph 148 a warning is issued that "none of our recommendations should be implemented in such a way as to require the precipitate substitution of asbestos or products containing it by alternative materials whose safety itself is unknown or in serious doubt". Furthermore the Report refers on various occasions (e.g. paragraphs 65 and 147) to the fact that ill effects from man-made mineral fibres are related more to the size and shape of the fibre than to its chemical composition. From this, the Report goes on to say, it follows that there may be similar health risks as in the case of asbestos and that one should therefore proceed with caution. We are struck by the fact that the conclusions and recommendations of the Report do not adequately reflect the arguments and principles so clearly developed in the main body of the text. On the contrary, the ACA expresses in its recommendations an opposite opinion by considering the controlled use of asbestos only as the last resort in situations where neither substitution nor prohibition are effective or appropriate. This is a position which the asbestos industry feels obliged to oppose. Specific Comments: (a) As to your first recommendation (a ban on crocidolite), the great majority of our Member Associations find it difficult to follow the reasoning that has led to this particular conclusion. It must be appreciated that other countries do not share the UK*s unfortunate history of the use of this material in spraying and other dusty applications and many therefore do not discriminate between the different types of asbestos fibres. Some which do so discriminate (e.g. Belgium) include in their regulations an exception for the use of crocidolite under supervision in the manufacture of asbestos cement pressure pipes. In these circumstances, and for the reason expressed in the next paragraph, we consider it would be more appropriate to keep the present regulations for the UK and in due course to conform with eventual EEC regulations. CAP CO JEN OOI2486 Miss S.C. Newton 3 4 March 1980 (b) The considerable disparity in regulations between the various countries of our Member Associations leads to the view that you should be aware of the need to keep broadly in step with legislation in other countries besides the UK (e.g. in the EEC), otherwise the UK could be put at a serious disadvantage in relation to its competitors overseas. (c) As we have already emphasised, the recommendations dealing with the question of substitution (Nos. 5 to 7) do not adequately reflect the careful reasoning within the body of the Report which clearly leads to the conclusion that, before alternative materials are eligible for replacing asbestos, it must be proved that these alternative materials1 are significantly less hazardous than asbestos. As to recommendation 5, we propose that such an obligation should lie with the primary manufacturer of asbestos articles who is in a more knowledgeable position to make the necessary technical evaluation v and judgement. (d) We strongly oppose.r&coromendation 17. Amosite is used extensively in all the countries of our Member Associations. Its use, however, is very largely confined to wet processes for the manufacture of asbestos-cement products and insulation boards. ^ Those Members who represent companies using amosite. are unanimous in their conclusion that the imposition of a 0.5 f/ml level on the use of any form of asbestos would be equivalent to a ban. In view of the fact that the use of amosite in pre-formed lagging or asbestos spray - the use with which Selikoff's various series of workers were involved - has virtually come to an end, such a severe and discriminatory regulation for amosite would be regarded as illogical and unjustified. Sir Neville Stack Director-General CAPCO JEN 0012487