Document QJDnnELN23n3RwpNzVBvB9KKE

ASBESTOS INTERNATIONAL ASSOCIATION .i (Limited by Guaranlce) 68 GLOUCESTER PLACE, LONDON WtH 3HL # TO: Member Associations FROM: Director-General AIA.'notes FOR ASSOCIATIONS > AIA/41/NEWS August 1980 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 Gommittee 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 Committee (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 view's through the Medical Advisory Panel, and our Scientific Advisory Panel gives us the considered opinion of eminent outside medical specialists on UCC 014586 A07396 /2 1 ' #, r ' AIA/41/NB/S JULY,I960 AIA NOTES TOR ASSOCIATIONS CONTENTS ITEM - ACTIVITIES OP PANELS SEC MATTERS NATO LABELS HASTE KBIBERSEIP CONFERENCES * LCV.'-EOSE INVESTIGATION RADIOGRAPHIC INVESTIGATION ACC-IH TJTCC/lLO X-RAY FILM AIA ADVISORY DOCUMENTS USEFUL PAPERS SELECTED REPORTS PR.QMCOUNTRIES U.5. H3P0RMATICN HEEDS " . ' ' PAP-AC-n^PS 1-21 22-59 40 41-43 44-45 46 47-55 56-5S 59-62 65-64 65 66-69 70 71-113 ATTACHMENT A073-97 UCC 014587 Member Associations AIA/41/NElv'S 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 - 2- m/41/hews JULY 1980 'A, I. A. MOTES FOE ASSOCIATIONS ; (Por Period July 1979 - July 1?80) EEC Advisory Council (EAC) (Chairman Mr. K. Thi-ele) 1. 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 Balangero mine and delegates also met representatives of the Italian asbestos industry. Details of EAC business are shown at paras. 22 to 39 below. Dust Measurement Advisory Panel fDMAP) (Chairman Dr. K. Bobock) 2. This Panel has held three meetings during the period: these were held in Neuss, Costa Eica and Cannes. The DMAP produced the Standard Reference Method (ETMl)fsee para. 66 below J) in time 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 DKAP sponsored the recent successful Third Dust Colloquium at Cannes on 10/ll/l2 June 19S0 (see paras. $2 and 53 below) which was hosted by the Chambre Syndics)? de l'Aniante (CSA) Prance. The next DMAP meeting will be on 3/4/5 September 19B0 at Denver, Colorado. The Medical Advisory Panel (HAP) (Chairman Dr.S.F. KcCullarh) 5. There have been two meetings of the MAP (their Jrd and 4th) in the period. The paper on standardising criteria for the diagnosis of asbestos-related diseases is nearly complete. 4. , 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. 5- 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. Eobock. The Study Group's terms of reference are: "To make recommendations on what the . AIA should do to encourage Member Associations 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 KAP'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.)" . The Building and Construction Advisory Panel. fBCAP) (Chairman Kr. 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 ITeuss 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. Ve owe a considerable debt to lir. Teichert and the Asbestos Institute at 1'Teuss. Acknowledgements and thanks are also due to those who have sent tools for testing from as far away as the western U.S. and eastern Australia. 8. It was hoped to have a draft of the Advisory Document ready soon for consideration by the Executive Committee but final agreement within the Working Party is proving more difficult than expected. The Fibre Producers Advisory Panel (FPAP)yChairman Mr. J.P.X.Ertcheson o./ * Following the Panel's meeting in June 1975 all major western fibre producers now show the "a" logo on their bags. This is a UCC 014590 A 0740C -4- 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. 10,, The new advisory document ''Asbestos Fibre Handling" (ECP 4) is now issued (see para. 66 below) and the first draft for the document on "Rag Opening" (see para. 67 below) has been written. . The Communications Advisory Panel (CAP) (chairman Mr. C.X. Latty) 11. This Panel has now 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 190 Montebello, Conference in Quebec on "Communications & Asbestos" (see paras. 50/51 ke-T-w). 12. The CAP has endorsed and the Executive Committee has now approved certain recommendations of the^ Hontebello.Conference. - Chief of these are:- 1. To hold a special Vorld Conference on asbestos & health during 1?81. 2. To assemble all papers concerning asbestos & health (this task is being undertaken by IEDA*). 5- To devote half a day of the 1981 Biennial Conference to Communications. 4* Countries who have not already done so to be advised to conduct a review of their national asbestos & health situations. 5. To have an AIA/lTA member on the CAP. 13. The CAP continues to advise the Executive Committee on immediate communications issues and has played an important part in drafting AIA comment to the UK ESE on the ACA report (see para. 101 below). Institute for the Research A Development of Asbestos - (A QAI-L1'/Quebec Government-funded Institute.) UCC 014591 407407 -5- Friction Materials Advisory Panel (FHAP) (Chairman Mr. 5. Doussier^ 14. 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 was held in London on 23 July 1930. Scientific Advisory Panel (ScAP) (Chairman Dr. J.C.-Gilson^ 15* The Panel met for the first time on 28 September 1979 after the IABC 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 U.S. this was very gratifying. The ScAP made two main recommendations enlarged on at paras. 16 and 19 below. 16. . 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. 17. V/hen such a plant had been located it should become the subject of a study which might well 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.) 18,, More recently the Chairman of ScAP, L^. Gilson, and Dr. Hans Veill have suggested as an alternative that we make a world-wide industry radiograph investigation. (See paras. 59 - 62 below.) They advise that this could have three results (a.) It might 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 407402 6- - (c) The figures could carry considerable authority since they would be on a world-wide basis. 19. 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 EEC Commission in such an undertaking. (See para. 33 below.) - Sealing Materials Advisory Panel (SMA?) (Chairman Hr. C. T. Dotty) 20. 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 *dvlsory Panel (TAP) (Chairman Mr. J.H. Karsh) 21. This Panel is producing three advisory documents (see para. 6?) concerned ` with manufacture', application and protective equipment. The EEC Commission - LG III Interests, (internal Market and Industrial Affairs) 22. A long-standing Council Directive (Directive No. 67/543/EEC 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. 23. 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 "carcinogen", but asbestos is clearly not proving easy to categorise. 24- A related Council Directive (Directive. ITo, 76/769/EES of ?7 July 1976) (which stems from "lirective Ko. 67/545/EEC) is one which governs the movement of Dangerous Substances between EEC member countries. This Directive is aboiit to be amended for the fifth time by a proposed Directive which would allow various types of asbestos to be used in certain ways. UCC 014593 -7- 25- 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 CDEEPER 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 Food (SCF) (a very prestigious body of distinguished EEC 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 Food - Ninth Series 1979'*. Reference 15 BN 92-325-1658-5. 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 Affairs) 28. The Directive on the Protection of Workers from Harmful Exposure to Chemical. Physical and Biological Agents at Work'(the "Framework" Directive) was adopted by the Council in June and should be published in the autumn. The Directive now includes a provision Allowing national legislation to be more stringent than the EEC's. The industry had been consulted during earlier drafting and the Directive is not in conflict with our interests. 29. Following from this "framework" Directive there will be nine "daughter" directives, cne for each dangerous substance listed and we are of course concerned with the one dealing with asbestos. Various working parties and committees on which we have spokesmen (notably Dr. Robock) are involved and our views are being taken into account. The plan is for this draft asbestos Directive to be submitted to the Council by early September I960. UCC 014594 Ao'<0 -0~ 30. 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/ml 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. 31. D.G.V asked the AIA (through Dr. Eobock) to contract for a report on dust measurement methods. The task was given to Hr. \1.H. Valton a noted dust expert and his interim report has been sent to the Commission. The final report is to be ready by mid-Se'ptember 19S0. 32. Ve understand that in the autumn, DGV are likely to start drafting a new directive which was to have been called "Carcinogens at the Vork Place" but which may now be called "Specially Dangerous Substances at the Vork Place". This will allow for the control of other dangercrus substances besides carcinogens (such as tetrogens and some others which are highly toxic ). The EEC Commission - DGXII Interests (Eesearch) 55- 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. However, at present we cannot persuade the EEC to move on this matter. The EEC Commission -- SEPCInterests (Environment and the Consumer) 34. The effect of emissions from factories into air and water is ' becoming of more and more interest to the EEC and the AIA is helping them to gather information for the formulation of a directive. The investigation is`being handled by T.1-T.0. (Toegedast Hederlards Onderzockscentrum) the Dutch research establishment who have sent a questionnaire to AIA Member Associations in the EEC to be answered by individual firms. Dr. Ioht-ing, in charge of the project, has recently asked if Greece and Spain (being prospective EEC members) could join in; this has been agreed. A 0? 40f> UCC 014595 -9- EITC - The European Parliament (E.P.) ' 55. 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 lTo.11 (Environment, Public Health St 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 members_of ' 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 East and Mr. Vanherle have already met the Chairman of Committee No.11 at Strasbourg; the Committee restarts its meetings on 22 September I960. EEC - The Economic & Social Committee (S.S.C.) 55. Following from para. 35 the same proposed .Directive has already ' been passed to the ESC for their opinion. Here the matter is being considered by the Section which deals with "The Environment Public Health and Consumer Protection". 37. 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" (Mr. 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. We are strongly opposing this. . Inter-Management *s Report on Asbestos and the EEC (The Hiedl Eeuort) 33. A closely argued report on asbestos and the EEC by Inter-Management (Tlie Hiedl Eepori) has been distributed to members of the Executive Committee and to member associates in the EEC (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 October 1979) and 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 viewpoint. UCC 014596 10 - 59- The Riedl Report also endorses close co-operation with UNICE * and CEFIC.+ (AIA has "been a member of TRUCE for over two years and has had useful connections with CNEIO through the Brussels office.) The report also recommends that the industry should make a particular effort through national industrialists to inform European H.P.rs 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. NATO Scientific Committee 40. lie learned that the Scientific Committee of NATO had become interested in asbestos and had asked T.N.O. (see para. 34 above) to initiate a study with a view to possible research funded by NATO. We made contact with the TNO investigator concerned (Nr. Pomerod) and are now involved in the early stages of planning the exploratory study. " Labelling . 41. The AIA "a" logo is now used on all bags of fibre coming from our most important mines. Vie 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 well as by the general public. Consumer lobbies around the world are increasingly insisting that what is on sale must be properly described and readily recognisable. Tie should keep moving with this tide; whether we do so or not lies in the hands of our members and 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 come to stay and the asbestos industry can bo no exception. 43- A draft schedule has been drawn 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 and updated as necessary thereafter. * Union of European Community Industries. + European Council of Chemical Manufacturers federation UCC 014597 - 11 Vaste 44. The AIA advisory publication on Vaste Uispesal (HOP 3) vas published in jnxgust 1979- (See para. 66 below.) The SEC Council Directive l?o. 78/319/ESC of 20 March 197S on "Vaste Disposal fox 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. 45- 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. Membership L6. Since the last 2.G.'s notes were VTritten, 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 and Yugoslavia are in the process of discussing the formation of National Associations. Argentina, Rraail and Korea have been in correspondence on this subject. Conferences TAJ1C Conference on the Biological Effects of Mineral Fibres held at- Lyon on 25/27 September 1979 47. Close to 300 eminent scientists from 26 countries gathered at Lyon - the conference was organised by the International Agency for Research on Cancer (lAHC) in cooperation with the Institut de la Sante . et de la Recherche sur le Cancer and the DM Medical Research Council's Pneumoconiosis Unit. This was intended to be a joint asbestos/felMF symposium but most of the papers presented were on asbestos because few KKKE research projects had been completed. 48- Nothing very new was discussed; perhaps this vas due to the fact that most available data refer to exposures- experienced 20-30 years ago. Ve of course urgently need health data on the effects of current low dust levels. However, the climate of 074 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. Mohock produced the AIA advisor:.' document on a Reference Method for the Measurement of Airborne Fibres at the Work Place (RTM l). The question of a dose/response relationship between asbestos and cancer was discussed and a number spoke about a "strai^it line'1 relationship. Mot many, however, spoke for an "acceptable level" of asbestos dose although many scientists present believed that there was such a dose level. Thus it is for industry to demonstrate this and to try and show how far above zero this level lies. Montebello Conference. Quebec, Canada. 10/l1 Anril 1950 on "Communications and Asbestos11 =0 A wide-ranging discussion at this QAKA-sponsored meeting at which there viere 55 participants from 12 countries emphasised certain areas in asbestos activities which needed attention. Hotably the importance of convincing the scientific body of the positive facts about asbestos and health which were beginning to come to light. The argument ran that medical and scientific views would then, in a positive wav, influence the media and those others who were the opinion-setters in our society. Once this happened the general public and government wouHfollow suit. . 51. The conference also recommended that there should be a world asbestos conference to be held within twelve months. This would provide a forum for scientists to discuss the asbestos and health question in an unbiased atmosphere and that hopefully as a result much of the distorted publicity which had been doing asbestos so much harm would be corrected. (The CAP Report at paras. 1l/l2 above gives further details of the recommendation AIA 5rd Dust Colloouiun - Cannes - 1p/ll/l2 June 19SQ ' The Bust Measurement Advisory Panel (DMA?) sponsored the Third Bust Colloquium at Cannes which was chaired by Br. Robock and Mr. Bouige and was attended by delegates from seventeen (17) countries. There wene sixteen (l6) government representatives (including 5 ministers from France); seventeen (l?) scientists; and twenty (20) industrialists. ' UCC 014599 15- - 53. The Colloquium was hosted by the Chambre Syndicale de l1 Andante (CSA) of Prance (President Hr. Cyril Latty) and covered many aspects of dust measuring techniques and strategy. These included progress and experience with the Eeference 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 1J81. Other Conferences 54. 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. 55* The list of conferences is regularly up-dated and circulated to Member Associations. The following are of particular interest;- 1. "International Symposium on "Water Distribution Systems and Related Health Problems" - Amsterdam 27/29 August I960. 2. "Fifth International Symposium on Inhaled Particles 1980" (British Occupational Hygiene Society) Cardiff 8/l2 September 1980. (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" Wroclaw,Poland, March 198I. (The Executive Committee has decided that the AIA should be represented at this Conference.) 4. "International Symposium on the Prevention of Occupational Cancer" (iLO/WEO/lARC) Helsinki, 21/24 April 1981. 5. AIA Biennial Conference, London 26/29 May 1981. 6. World Conference cn "Asbestos-Health & Society". . (IRDA, Canadian Government & AIA) Montreal - 1981. (See para. 51 above.) UCC 014 ic - 14 - Cuestionnaire on Low Pose-Areas 56. The questionnaire to find out where we night 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 past. 571 . 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 made 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. 59. VTe have, however, had seme information as follows 1. Ten (lO) plants (out of a possible 10C0 + 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 (3) companies reported that they have low dose investigations going on in their various plants. They could not say when those projects would be finished. . - Badiographic Investigation 39. The disappointing response to the AIA questionnaire was discussed with the Chairman of the Scientific Advisory Panel (TcAP), Ir. Gilson, and with one of the panel members, Professor Hans brill, who was in the tl.IC. on a visiting professorship. Both considered that the AIA with its universal members'hit) including many technically very advanced companies had the capability of providing X-ray health data about its wark force which, if properly presented, could be most convincing evidence to chow to world scientific opinion. What was more, th evidence wap immediately available; time would not be s;-- Jin, having to set up an epidemiological study - "tils t^oc-Xsia of course would be in evaluating the radiograph readings which vero available; but this is purely a mechanical problem.' A074]1 UCC 014601 - 15 - 61. The readings could well show initially that the state of health of the asbestos industry's workforce world-wide was much "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 U.K. Coal Board findings on a similar scheme concerning pneumoconiosis) the incidence of asbestosis would be seen to be decreasing rapidly in the lower age groups. 62. 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 4 plants have replied from 11 countries. The American Conference of Government Industrial Hygienists fAGGIE) 63. ' 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 ACGIE to protest that such a standard would virtually ban the use of Amosite and Crocidolite. 64- The ACGIH Committee on TLYg was put in touch with Dr. Robock some months ago and hopefully he and the DMAP may be able to persuade ACGIE to think again. U.I.C.C,/l.L.O, X-ray Film Classification The MAP have reported that a revised standard set of films has been produced for the ILO 1579 International Classification of Pneumoconiosis, The set can be obtained from- ILO Publications, International Labour Office, * CH-1211 GENEVA 22 (Swi tzerland) at n cost of Swiss Francs AGO nor set. 4/0? UCC 014602 - 16 - AIA Advisory Documents 66, The following documents, Recommended Control Procedure (RCP), and Recommended Technical Method (RTK), are available 1. RCP 1 2. RCP 2 3* RCP 3 4. RCP 4 5- RTM 1 The Control of Asbestos Dust (also available in Italian). Asbestos Cement Products (also available in Italian). Asbestos Waste Disposal' (also available in Italian). Asbestos Fibre Handling (also available in Italian). Reference Method for Measuring Asbestos Fibres at the Workplace (also available in Italian and being translated into French and Spanish), ' 67. . 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 P,CP2) (being translated into Italian). 2. Rag^-opening. 3- Friction Materials - manufacture, 4. Friction Materials - maintenance work. 5- Textiles- manufacture. 6. Textiles - Manufacture of user articles. 7- Protective clothing. 8. Demolition and Stripping. 68, In addition two leaflets are available 1. The Industry's Viewpoint Concerning Asbestos. 2. A Digest of Information Concerning the Association. *0. 4/ V? UCC 014603. - 17 - 69. A background position paper "A.sbestos 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. "CEO - 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 TITO (Dutch Research Institute) - Mr. banting. 3. "The Health Hazards of Asbestos", M. Ueuberger (Siohere Arbeit, Ho. 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, U.Y.). 6. "FC Drinking Water Pipes - Incidence and Evaluation of Asbestos Fibres in Drinking Water". (Amianthus Centre. Compact - Information - Pipes, 80-1,May I960.) 7. "An Investigation of the Use of Asbestos Cement Pipe for Public Water Supply and the Incidence of Gastrointestinal Cancer in Connecticut 1955-1973". (Harrington, Craun, Meigs, Landrigan, Flannery & Voodhull - American Journal of Epidemiology, Vol. 107, Mo.2). 6. "Asbestos Cement Pipe and Cancer in Connecticut, 1955-1974" (Meigs, Walter, Heston, Killette, Craun, Woodhull & Flannery - Journal of Environmental Health, January/Pebruary I960), 9. "Is there a risk to health in using asbestos-cement pipes for the carriage of drinking water?", (S.F. McCullagh, I960 - Ann. Occup. Eyg. Yol.23, p.169). . . 4 /4 UCC 014604 18 - 10. "A Hational View of Cancer in Hew Jersey" (Dr. E.E. Demopoulos when Director of the Cancer Institute of New Jersey). 11. "Environmentally Induced Cancer ... Separating Truth from Myth" (Dr. II.B. Demopoulos - talk to Synthetic Organic Chemical Manufacturing Association Inc.). 12. "Cancer in Modem Mortality" (Publication of the TJ.K, Chemical Industries Association). 13- "The Prevention of Occupational Cancer: an ASTKS Policy Document - A Review by Dr. J. Xeir Howard" (TJ.K. Chemical Industries Association Background Paper, 20 June 1900). 71. The following paragraphs cover those countries in which, there has been significant activity, L egislatiou is only reported where some amplification is needed of the consolidated schedule circulated under AIA Memorandum ref, AIA/12/P.ZG dated June I960. ` Details of events in all associate countries as reported by members are shown at the Annex to Governing Council Minutes. Australia 72. A small sub-committee within SPAA has been set up to consider ways.of countering union pressure against asbestos. Austria 73 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 factory doctors, scientists and engineers. Details are awaited. . Belgium 74- 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 adequate there is no problem. The regulations concerning finished products are reasonable and acceptable to industry. Canada /6 75- In December 1979 the Canadian Government sent a deputation of officials, scientists and doctors to Washington to protest at the UCC 014605 - 19 - unnecessarily stringent rules concerning asbestos and its use which were being proposed by the 11. G. regulatory authorities. The Canadian deputation discussed the problem with OSEA, EPA and CPSC officials and explained Canadian concern. 76. A tripartite group (governaent/industry/workers) from Germany is being invited by the Canadian government for talks and a visit to an asbestos mine. A French group vas invited by the Quebec government in December 1979 for a similar purpose and this party included Messrs. Latty and Join and Professor Bignon. 77* Dr. Bunnigan has been appointed Director General of the Institute for the Research and Development of Asbestos (IRDA) in February I960. He had been Director of the asbestos research programme at Sherbrooke University and IRDA's headquarters will be on the university campus. 78. The Chairman of the IRDA Board of Directors is Mr. Michael Prus, Chairman and President of Carey Canadian Inc.. The other six members of the Board (3 industry and 3 government) are: ' Marcel Dorais, President of Les Mines d'Aniante Eell Ltee; J.R.-M. Hutcheson, Chairman of Johns-Manville Canada Inc.; Andre' Marier, President and G.K, of Centre de Recherche Industrielle de Quebec; M.J. Messel, President of Lac d*Andante du Quebec Ltee: Daniel Perlstein, President of Societe Mational de l'Amiante; Andre Saumier, Senior Advisor, Plchardson 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. 79* All aspects of health research will continue to be the responsibility of IOEH whose budget for 1080 is Canadian $ 810,700 (funded by fibre producers). Since it started in 1966, I0EE has spent Canadian $ 6,195,400 and published 149 papers on matters to do with research into asbestos and health. SO, A Royal Commission will sit in Ontario in September IJSO to report on asbestos - the hearings are expected to last for a year and QAKA are preparing to play a part. 11 6 UCC 014606 - 20 - Denmark The list of asbestos-containing products allowed by Danish lav is as follows:- . 1. Unbonded Packing Materials .2 A/C Products (max, 2C/ asbestos by weight) until 1 April 1982 until 1 January 1985 3. Commutators (max. &CF/c asbestos by weight) until 1 January 1990 4. Friction Facings (maximum 20;; asbestos by weight) no date limit 5. Eonded Packing Materials (max. 2C?S asbestos by weight) no date limit .6 Linings (max. 20?-i asbestos by weight) no date limit 82. It-u.s most important that the asbestos industry should be able to convince world 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 C4, 4 recent decision by the Minister for Health to ban the use of asbestos filters for.food and drink i:as the subject of a protest by the Chambre Eyndicale de 1'Ami ante (CSA.), cur French Aissociation. This 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 1? UCC 014607 - 21 above) and the German Government Health Department have recently excepted asbestos filters from a ban which they have put on some other articles (see para. 52.2.2. below). The French Health Department is also investigating the use of asbestos in certain household articles with a view to limiting their use. 85- Dr. Eulah Bingham held an informal meeting in Paris on 27 June 1980 with government representatives, certain doctors including Professor Bignon and Dr. Sebastien and one industry representative, Mr. Douige. A report of this meeting was circulated to Member Associations (ref. AIA/l/4/8/POL dated 14 July I960). Dr. Bingham was not very helpful in her comments on the asbestos situation in the U.S.A. 86. The Minister for Health has indicated that the government would be prepared to reduce the exposure level to 1 f/ml if the EEC agreed on this figure. There was no intention of going to any lower . figure. Germany . 87. 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. 83. Haw 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 XIO Convention I7o,159) 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 and of Labour, the current draft regulation concerning asbestos includes the following:- 4o'</a UCC 014608 - 22 - (a) various limitations to be imposed on working time if the TLV is above a certain level (still to be laid down - but possibly 1 f/ml); (b) asbestos-containing products to be accompanied by label instructions referring to the Raw-Material Regulation; (c) reasons for using asbestos products instead of substitutes to be stated to the local labour authority. 89. 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. 90. Industrial Catastrophe Regulation Again after much discussion, the asbestos-processing industry will not be included under this Regulation. However the Asbestos Corporation at Uordenham will be included because of its large stocks of raw asbestos. 91 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. 92. Industrial Safety Regulation (lust) - Second a insnduc1n*t 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 laws. The SC- recently passed a second amendment to the Industrial Safety Regulation (bust). 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 of asbestos products which are banned. These were:- UCC 014609 - 23 - 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 0.5 f/ml). 93. Special Meeting The~BG Supervisory Board organised' a special meeting on 6/7 March 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. 94- The Media 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. 95* 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 Eobock, presided and the scientific technical panel (the Scientific Working Group on Asbestos) with Dr. Bohlig as Chairman also attended. The object was to give the true facts about asbestos to selected journalists interested in asbestos. UCC 014610 - 24 - 96. Federal Environmental Protection Arcncy (Llaw-oltbnr.desant) This Agency has recently directed all its activities (research programmes etc.) to assessing what danger to the environment is posed by asbestos. 97. Hse of f/litre Those German ministries concerned with asbestos are now using the f/litre scale and not f/ml. Netherlands 98. A new regulation has banned asbestos in household articles (irons/toasters). ' 99. A Tripartite Committee has been set up to advise the government on asbestos matters. It consists of employers, experts, and ' trades union members. One of the members from industry is IIGoedmann. ' ICO. A recent television programme on factories and the environment had shown the Goor Stemit factory as an example of excellence. 101. F.g. The Advisory Committee on Asbestos (ACA) popularly knora as the Simpson Committee (after its Chairman) issued its recommendations in December 1979* These have been fully reported elsewhere; among the total of 41 recommendaticns most of them are, with some reservations, acceptable to II,II. 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 some considerable time. yet. 1C2. A (draft) Cede of Practice and Guidance Note unde: the Health and Safety at fork Act is about to be issued. It covers work with asbestos insulation and with asbestos ccatin; a and deals with personal protection, plant and process control ani . asbestos waste and has industry's full support. 4 UCC 014611 - 25 - 103. 104. 105. 106. 107. TJ.C.A. 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/ITA 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/lIA 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/NA decided to retain a law firm to advise them on:- (a) Rule-making processes. (b) Possible future legislation. The Advance Notices of Proposed Rulemaking (AUER) which were issued by EPA and CPSC in 1979 were strongly argued against by AIA/lTA within the deadline set for response (18 February 1980). The AIA/NA 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 propose any regulation under the Toxic Substances Control Act (TSCA). Members may be interested to know that the law firm retained by AIA/PTA had been earlier retained by the II. S. Chemical Industry who were contesting an CSKA-imposed workplace standard for benzene ten times more stringent then 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 prove at what level any new OSHA standard should be set. This decision is bound to have a far-reaching impact on all H.S. Government programmes to control carcinogens and, for example, will have a bearing on OSKA's stated intention of reducing the UCC 014612 - 26 - 103. 109. 110. present 2 fibre/ml workplace standard for asbestos. If the new precedent is followed, OSEA will have to prove: (a) that 2 f/ml is unhealthy; (b) what is a healthy lower level. OSHA has announced that action is to be started on asbestos rule-making during' 1980. The standard to be proposed nay follow recent recommendations to OSHA which were made by a research institute (the Research Triangle Institute) (R.TI) which suggested that it was possible to manufacture at the following exposure levels:- Most products (except dry woven textiles) 0.2 f/cl Automotive after-market 0.2 f/al Shipbuilding 0.5 f/ml Secondary fabricators 0.5 f/ml Construction 0.5 f/al (except for removal, maintenance and demolition) Ship repair 2.0 f/nl Whether OSHA accepts these levels as practical for rule-making remains to be seen. The time-table for expected OSHA legislatory initiatives is roughly as follows:- Advance ITotice of Proposed Rule-Making (AHPR) - July/.August 1980 Proposed Rule - Sept./October I960 Public Hearings - Feb./fearch 1981 (?) Final Rule May/June 1981 The SPA 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. HPA recognises that in order to minimise the impact on industry the timing of any effective dates could range from 1989 to 1995 snd possibly later, resulting from any judicial appeal. UCC 014613 - 27 - .111 .112 115- The tine-table for expected EPA legislatory initiatives following their AlfPR is approximately: AFFR was published October 1979 Proposed Rule ^December 1990 (?) Public Hearings (?) 1991 Final Pule (?) 1992 AIA/I'A's lawyers need to assemble as much information as possible in order to prepare their case and a list of AlA/NA'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/tIA. However, if you have not already been contacted by this office .to forward information to AIA/?TA and if you feel that you may have information which could be useful to them, please send the data directly to AlA/t7A (plus copy to this office, please). aia/ai/iip, August 1980 Attachmenb: "Summary of information Feeds for United States Regulatory Proceedings". 4, UCC 014614 < Attachment to AXA NOTES EOR ASSOCIATIONS JULY 1980 SUMMARY OF INFORMATION NEEDS FOR UNITED STATES REGULATORY PROCEEDINGS 1. 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. 2. Studies of the eventual fate of once-released asbestos fibers. 3. Studies of the accuracy and validity of measurements made by the membrane filter method, especially at levels below .5 fibers/cc. 4. 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. 5. Medical evidence from individual asbestos companies, especially if unpublished, of the health effects observed in their employees. 6. 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. 7. Documented historical information of the levels of asbestos exposure among asbestos employees, especially at plants where epidemiology studies have been conducted. 8. Current asbestos exposure levels at all stages of the mining, milling and manufacturing process and during product installation and use. 9. 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. 10. Analyses of the economic availability, efficiency and medical effect trade-offs inherent in various suggested substitutes for asbestos or asbestos-containing products. UCC 014615