Document QXqYX8pRV3by9YYpNd1GpOw0v

OCTOBER 1992/JANUARY 1993 THE ASBESTOS INSTiTJXTE a' e rt s i h 1 a. rn a n a g e rn e ri t n at u r a l No Excess Lung Cancers Detected From Chrysotile Exposures Less Than 50 Ecc Important Study Finds That at Exposure Levels Below a Threshold of 50 f/cc, Chrysotile Asbestos Is Not Linked to Any Increased incidence of Lung Cancer. Preliminary results from the largest cohort study of chrysotile workers ever undertaken were released this past September at the 9th International Symposium on .Epidemiology and Occupational Health held In Cincinnati, Ohio. The study, conducted by Doctors t'.D.K. Liddell, A.D. McDonald andJ.C. McDonald of McGill University evaluated more than 11,000 chrysotile miners in Quebec bom between 1891 and 1926. Initiated in 1966, the study was designed to define as accurately as possible the quantitative relationship between expo sure to chrysotile asbestos and the Inci dence of lung cancer. Cohort data has been collected five times since, the latest in May of 1992. Based on exposure data gathered-by the mines, and comparisons of Standard Mortality Ratios (SMR = observed mortal ity / expected mortality) the authors con cluded that any excess cancer mortality was found only among workers exposed to more than 50 E/cc for a period of 20 years or more. (see No Excess Lung Cancer onpage 2) ! Inside ! Previous Data on Chrysoclle , ,i_ Exposure Support New . "`f iE/nr. Findings A/C Pipe Makes a Resurgence in the U.S. F.PA's Science Advisory Board Critical of Agency's Asbestos Program ; Overrunning the Verdict on j Carcinogens i 1 Code of Practice for Synthetic Mineral Fibres j U.S. Study Links Fiberglass to ' Lung Disease Policy Considerations and Theory, Not Science Have Guided Asbestos Regulations For yoar^ tho linear mod! of risk analysis has been applied to the regulation, of-;chrysotile asbestos expo sure. Today scientists ai*e ijiifestionlng the validity of this approach. The linear model er risk analysis holds that a substance which is toxic at extremely high doses *fian have a health Impact at levels many orders of magni tude lower - even If there are no observ able effects at these' levels. The linear model maintain thit efiedts may exist, yet are not detectable with current tech niques. This model has traditionally served as a guideline for setting exposure limits and other regulatory action. In the face of mounting evidence that for many known carcinogens there appeais to be a threshold level of exposure below (see Policy Considerations onpage 4) HWBUI0005355 "EB 5 ,l?3 i3:29 ft_s prtctION MAIL'S P.3 No Excess Lung Cancers ... This landmark study confirms the find ing of other less extensive research which has found no excess mortality risks result ing from low-level exposures to chrysotile asbestos. For example, Churg (1986) dis- ' covered that residents of chrysotile mining communities who were exposed to fibre levels from 200 to 500 times higher than those common in most North American cities showed no evidence of a higher inci dence of asbestos-related disease. Other studies examining work place exposures have corroborated these findings. Newhouse & Sullivan (1989) conducted a 40 year mortality study in a factory pro ducing chrysotile-based friction materials. They concluded that despite exposure lev els substantially higher than those cur rently found, chrysotile asbestos was processed with no detectable excess mor tality. Similar findings have also been observed in studies of chrysotile exposure in the asbestos/cement industry (Ohlson & Hostedt, l935;Thomas et al, 1982; Weill ctai, 1979). Previous Data on Chrysotile Exposure Support New Findings Although the Liddell, MoDonald & Mcdonald study is the largest and most thorough cohort study to date, a number of scientific antecedents support its conclusions. Churg, A. Lung. Asbestos content in long-term residents ofa chrysotile mining town. American Review of Respiratory Disease, 1986,134(1): 125-127.. Study comparing health effects in residents ofchrysotile mining towns, where levels arefrom 200 to 500 times higher than m most North American cities. In spite of bigfter levels, no evidence ofhigher asbestos-related disease wasfound. 9 Newhouse, M.L. and Sullivan, K.R. A mortality study ofworkers manufacturing friction materials -.1941-86. British Journal of Industrial Medicine, 1989, 46(3): 176-179 The authors confirm that there was no excess mortality from lung cancer, other asbestos-related tumours or chronic respiratory disease. 9 Ohlson, C.G. and Hogstedt,C. Lung cancer among asbestos cement workers; ASwedisb cohort study, and review. British Journal of Industrial Medicine, 1985,42(6): 397-402. r ,, A cohort study of1176 Asbestos-cement workers in a Swedish plant using chrysotile asbestosfound na excess mortality at exposures ofbetween 10-20f/ml. .iff. ,, The Liddell, McDonald & McDonald'" *,r - Thomas,sgenjamin, LT.,Efwood, P.C. and Sweetnam, P.M.. Furtherfollow-up report not only supports thaS3 previous.... findings, but it makes-a slgni&spLnew .. study of workersfrom an asbestos cement factory. British journal of ',7r IndifStiial Malidine, 1982, 39(3): 273-276. contribution to our understanding of the nature of the threshold level of exposure A follow-up study of 1$70 workers in an asbestos-cementfactory using chrysotile only showed nopigrtificant Standard Mortality Ratio (SIM) excesses. The causes of death investigated included neoplasms and cancers of the lung, pleura and gas responsible for inducing chiysotile-related trointestinal tract, disease. In terms of its implications for Industrial hygiene policy, the study pro vides compelling evidence that the conuolled-use approach to chrysotile asbestos is not only feasible, but given that current exposure levels around the world are fre-'5 >' quentiy l f/cc or less, it Is the most logical Weill,H., Hughes, J. and Waggespack, C. Influence of dose andfibre type on ,respiratory malignancy risk in asbesos cement manufacturing. American ; Review of Respiratory Disease, 1979,120(2): 345-354. 'An investigation of 5,645 asbestos-cement manufacturing workers found no increased mortality resultingfrom chrysotile exposures ofapproximately 15f/ml. years. regulator/ option. 2 HWBUI0005356 FEB EE '93 13=30 h-S FRICTION MAIL'S P.4 A/C Pipe Makes a Resurgence in the U.S. After several years of uncertainty, the overturn of the ban on asbestos products in the U.S, Is beginning to revitalize its asbestos cement pipe industry. Following the reversal of the U.S. Environmental Protection Agency's. (EPA) ban rale many water authorities are considering returning asbestos cement (a/a pipe to their specifications. Although it has long been recognized tor us superior durability, performance and relatively low cost, the introduction oi any new :vc pipe systems nad been ali but eliminated by the EPA ban mie. In its ruling sinking down he ban and phase-out of mosi asbestos products, the Fifth Circuit Court of Appeals concluded that no substantial evidence was oreSen ted to support ct Din oi ishtstos didc. In fact oruceedinRS did mors to rs.!$ concerns regarding the health risks or competing products such as PVC or duc tile iron nice With the reputation of VC pipe churl'.' restored, so too arc me prospects for xs manufacturers. In June or 1992, the West San Bernadino Water District officiallyannounced that because of the reversal of the EPA ban, it will henceforth return , .VC pipe to its specifications and sane- j lion its installation. Several other city ! water agencies have followed suit with similar announcements, and many more are considering returning a/c pipe to their specifications. In addition, the Bureau of Reclamation, a long-time user of a/c pipe and a U.S. Government agency has tevoked its moratorium on its installation and has returned it to its material specification list. The Bureau explained that changes m technology and controlling regula tions have made it possible to work safe ly with VC pipe and have minimized the environmental concerns once thought to be presented by its use. S I Prior to the EPA's ban, A/C pipe's techni cal and cost advantages resulted in more 500,000 km's being installed throughout the U.S.. Although the process of rebuilding the VC pipe mar ket will be a lengthy one, these laiest developments are an encouraging sign for the industry'. * .in in-depth Special Report on jthe advantages of,i/C pipe is available through the Asbestos Cement Pipe Producers Asso ciation (ACPPAJ or the Asbestos Institute. EPA's Science Advisory Board Critical of Agency's Asbestos Program In a letter to EPA Administrator William K. Reilly dated .April 21, 1992, the. U.S. Environmental Protection Agency's Science Advisor, Board (SAB) was criti cal of the agency's regulatory approach on asbestos. The comments of the SAB followed a public meeting held on Feb. 24-25,1992 of SAB's Indoor Air Quality and Total Human Exposure Committee which Included several presentations by EPA officials. Amongst other things, the SA8 ques tioned the scientific basis for past EPA regulatory action regarding asbestos and criticized its research programs which appear to be based on outmoded notions of which fibres need to be measured and controlled...". in terms of the risks of substitute fibres, the SAB had this to say;" It is possible that replacement fibres for asbestos in products and buildings may be as haz ardous or more hazardous than the asbestos products they replace. Such research [on the critical issue of fibre propertiesj is needed if the Agency is to make scientifically sound policy deci sions regarding asbestos and substitute products." 3 HWBUI0005357 FEB Z5 'y3 13: dl H-b FRICTION tlftlL'b Policy considerations... which there are no detrimental health effects, many scientists are recommending that we rethink our approach to risk assessment As such, legislators are asked to recognize the limitations of the linear model as a basis for regulatory policy. quently been used as the principal instru ment for determining chrysotile exposure limits and regulatory policy'. The reality is that once a risk estimate is calculated and published, regardless of its validity or accuracy, it can be 'used as a platform to justify unwarranted and extreme action. " stringent regulation andfright ening publicity have led to public anxiety and chemophobia... the cost ofcleaning up phantom hazards will be in the hundreds of billions ofdollars with minimal benefit to human health. In the meantime, real hazards are not receiving adequate attention." P. Abeison .vssociace Editor, Science Scientific Limitations of the Linear Model There are a number of serious problems which can arise from applying the linear model, of risk assessment which extrapo lates from high dose exposures to much lower ones. Any of a number of experi mental flaws can alter the slope of the dose-response curve and result in an inac curate estimate of risks at the low end of the exposure scale. Experimental errors, and the effects of insufficiently large data pools or slight variations in chemical composition are magnified many times over as data from very high doses is extrapolated to very low doses. The end result is that predictions based on the lin ear model have resulted in gross exagger ations of the. actual health risks and car cinogenicity of many substances at low levels of exposure. This has clearly been the case for asbestos. The actual number of asbestos-related cancers observed in the U.S. is more than 20 times less than the original estimates based on the linear extrapolations of Dr. Irving Selikoff and the (J.S. Department of Health Education and Welfare (HEW). Despite these and other serious limitations as well as the existence of other more real istic interpretations of the data, extrapola tions from high dose exposures have fre All Substances are Potential Toxins Supporters maintain that it is prudent to err on. the side of caution. They believe that although at low doses no carcino genic effect may be observed, it is possible that these effects exist, but are unde tectable with current data and methodolo gy. In theory, this is true. Zero risk for any substance cannot be proven with absolute certainty, nor will it ever be. Clearly all substances are potential toxins and can never be proven to be without risk. This incLudes exposures to common and essen tial substances such as salt, water or even oxygen. At very high doses any substance can be carcinogenic and the risk factor will always decline as the dose declines. Conversely, even the most toxic substances, such as arsenic are not only safe at..low doses, but necessary to our survival. The challenge for regulators, with the assis tance of scientists, is to determine what level of safety is acceptable. In the case of chrysotile asbestos and many other sub stances, the linear model of extrapolations lias proven ineffective. The high level of uncertainty in extrapolating from high doses to much lower ones is beyond that which is acceptable. It has led to misinfor mation, unrealistic risk estimates and ultimately to ill conceived and unrealistic regulations. HWBUI0005358 H-S FRICTION MOIL'S P.6 Redefining the Basis for Regulatory Action Today many scientists believe that extrapolations should be restricted to one order of magnitude outside the observ able range (see article on National Toxicology Program). As the faulty risk Overturning the Verdict on Carcinogens estimates for chrysotile have demonstrat ed, extrapolations below this range are Review Board Say* not reliable, accurate or useful In addi Methodology for tion, the notion of a threshold level of Classifying Carcinogens cancer induction is gaining acceptance is Rawed; Questions in die scientific community as well as in validity of existing tlic regulator/ arena. Research such as procedures. uie Liddell, McDonald and McDonald 1 study provide compelling evidence for | In a surprising announcement, an Ad- die existence of a threshold for chrysotile ] visory Review Board established by the related disease which is many times U.S. National Toxicology Program (NTP) higher than currently acceptable expo has questioned .the scientific basis for sure limits. Critics may say that in theo ry, even though no increased cancers applying the concept of Maximum were observed below 50 f/cc, it is possible Tolerated Dose (MTD) In identifying that chrysotile has a carcinogenic effect and classifying human carcinogens. The that is not detectable. If there is no review board concluded that two thirds observable carcinogenicity and no of NTP carcinogens would no longer be increased Incidence of cancers, and tills identified as such if the MTD was not has been shown time and again through used. "The implicit assumptions under numerous studies across different popu lying extrapolations from the MTD... do lations, perhaps the issue of theoretical not appear to be valid." risk is a moot one. Regulators must look . at the observed threshold, consider an adequate safety factor and determine exposure limits based on the strength of human epidemiological data. Sources: Vubiana. M . Tua CarcinogenicEffect of Low Doses of Carcinogens. British Journal of Industrial Medicine, 1992; 49:601-605 :\s its name implies, the MTD method involves injecting laboratory animals with the highest dose compatible with bare survival. Based on their response and the level of cancerous effect pro duced, predictions are made regarding the carcinogenicity of vastly lower expo sures in humans. Karris. W E.. Lotv-Dosa Risks and The NTP Review Board noted several Authoritative Misinformation. Department of Chemistry. University of Alberta, 1991 major concerns with the MTD method- jAbcison. Pa., Testingfor Carcinogens wub oiogy employed. In particular It ques- Rodents. Science, 1990, 249:258. I tioned assumptions about the rate at which substances are absorbed at differ ent doses; the linearity of the doseresponse relationship; the rate at which the body repairs genetic damage at dif ferent doses; and the generalizability of data from animals to humans. G.B. Gori, the former deputy director of the Cancer Cause and Prevention Division of the National Cancer Institute comment ed that "some of these assumptions are intuitively questionable and, as the report makes clear, there is now ample evidence and widespread consensus that they are scientifically untenable." Mr. Gori goes on to say that despite fun damental flaws in the MTD methodolo gy, these studies " have been the basis of far-reaching regulatory actions costing the U.S. economy billions of dollars." Moreover, he believes that these mistak en assumptions have created and sus tained many of the myths.associated with the pervasive fear of cancer in our society. " Most regulatory policy in the U.S. has been based on the twin dogmas that ani mal and human susceptibilities to car cinogens are equivalent, and that `no effect thresholds' at low doses do not exist Both have been the philosophical underpinnings of most health and safety regulations regarding carcinogens for more than $0 years. Both are faulty assumptions that the Advisory Review Report now questions." concluded Mr. Gori. 5ourcc: The Wall Street Journal, Aug 27, 1992. 5 HWBUI0005359 rEB 33 -33 13:33 h-S FRICTION MAIL'S P.7 U.S. Study m Links Fiberglass to Lung Disease Does prolonged exposure to fiberglass adversely affect pulmonary functions or produce radiographic abnormalities in humans ? a recent study by researchers at the University of Southern California (DSC) School of -Medicine concluded that com mercial rotary spun fiberglass appears to produce human disease that is similar to asbestosis. The study, conducted by K. Kilbum, D. Powers and R.H. Warshaw was published in the October issue of The British Journal oj Industrial Medicine. it examined 2St workers at an appliance factory where refrigerator doois and cabi nets were insulated with fiberglass sheet ing and loose rotary spun i'iberglass.Workers with exposures of twenty rears or more were evaluated on a num ber of tests of respiratory functioning including iung volumes, chest x-rays and physical examination. A postmortem analysis of one worker who died just prior to the study showed a sub stantial accumulation or glass fibres in the lungs. A transmission electron microscopy examination showed that each lung contained approximately 173,000 fibres. Charles Rossiter, former professor at the London School of Hygiene and Tropical Medicine who currently acts as a consul tant to the Insulation industry disputes the study's conclusions. He argues that the study does not adequately recognize the compounding effects of smoking and that the control group was not represen tative. Me Rossiter does nonetheless urge the Man Made Mineral Fibre industry to undertake further study into the health effects on users. Jim Merchant, a leading American authority and director of the Occupa tional and. Environmental Health Department at the University of Iowa believes that this study is " in line with what we know about fiberglass". Mr. Merchant warns that "this may have a lot of implications for people who work in building and construction." Other major American and European cohort studies of the occupational health risks for workers in the Man Made Mineral Fibre (MMMF) manufacturing sector have found lung, trachea and bronchus cancer rates in excess of those expected. Tire researchers found that in addition to eye and throat irritation in about 20% of the population studied, expiratory flows, which Indicate pulmonary dysfunction, were significantly impaired. 43 workers also had evidence of pneumoconiosis on chest radiographs. The authors believe mat 33 (13%) cf these pulmonary' opaci ties or plural abnormalities were due to fiberglass exposure. Sources: Marsh, GM,, Enterline, P., Stone, R. & Henderson, Vi., Mortality among a Cohort of USD Mdn-Made Mineral Fibre Workers: 1985 Follow-up. J. Occ. Med. 32, 594- 604, 1990. Slroonato, L et at. The man-made mineral fibre European Historical Cohort study: Extension ofthe Follow-up. Stand. J. Work, Env. Iflth, 12, Suppl 1, 34-47, 1986 Code of Practice for Synthetic Mineral Fibres In response to recent human, and ani mal data, representatives from the Quebec Federation of Labour (QFL), with the support of the Canadian Labour Congress have written a draft Code of Practice for the use of Synthetic Mineral Fibres (SMF). The code would include descriptions of SMF, summaries .of their health effects, as well as recommenda tions for proper monitoring, safe work practices and exposure limits. The code would detail work practices based on the different risk factors accorded to various fibres. A number of recent studies (see article U.S. Study...) have found evidence that exposures to some types of SMFs can have serious health effects, including eye and throat irritation, pulmonary dys function, non-mallgnant disease and cancer. Despite the growing concerns of scientists, regulators and the labour movement, some industry representatives such as Frank Careghini, manager of Occupational Health and Safety at Owens-Corning/FIberglass Canada maintain that insulation fibres are not carcinogenic. A new Code of Practice is intended to eliminate the inter-provtnciai inconsis tencies which exist in worker protection policies across Canada and provide, guidelines for government policy and industry practices. ^. 1002 Sherbrooke Street West Telephone: (514) 844-3956 5 jttk' THE ASBESTOS Suite 1750, Montreal (QutSbee) Telex: 055-60565 (INSTXM) INSTITUTE Canada H3A. 5L6 Telecopier: (514)644-1381 HWBUI0005360 JUNE/SEPTEMBER 1992 THE ASBESTOS INSTITUTE wm UNCED AND ASBESTOS For many organizations, the economic development for the conclusion of the United 21st century. This plan of action Nations Conference onis called AGENDA 21. agement of Toxic Materials. Specifically, this section of AGENDA 21 addresses the Environment and Development "beneficial use of chemicals for (UNCED) marked the beginning One component of AGENDA sustainable development and safe of another process; that of 21 is the formulation of manufacturing with minimum revision, evaluation and analysis. recommendations regarding the risks to health and environment * Each is taking stock of what Environmentally Sound Man (see AGENDA 21 on page 2) transpired, both positive and negative, and what the implica tions are for the future. Earth Summit background The experience of The Asbestos Institute (AI) at UNCED is perhaps represen tative of the difficult task of arriving at global environmental solutions. On the one hand, AI witnessed the detrimental impact, which strong sectoral and national interests can have on environmental problems, as well as the potential, which exists for developing intelligent solutions to complex environ mental issues, based on the strength of scientific evidence. AGENDA 21 The principal goal of UNCED was to achieve consensus among nations on a plan of action on issues of the environment and of INSIDE.,.. s In search of zero risk Experts and risk Dangers of RCFs 8 Risk assessment UNCED may have boon the highest and most ambitious global summit on the environment, but it has a number of predecessors to thank for setting its course. The first such global summit was held twentj years ago. The Stockholm Conference of 1972 was one of the first major steps in bringing environmental protection to the UN agenda. It was attended by 1,200 delegates from 113 countries. In some ways, this ground-breaking conference set the tone for future international discussions concerning the environment and development It defined and set parameters for monitoring many of the global environmental concerns which were on the discussion table at RIO. At the same time, it was a foreshadowing of the types of disagreements which blocked progress in several areas at UNCED. As far back as 1972, the lines were clearly drawn between the interests of the developed and the developing countries, between North and South. One of the highlights of the Stockholm Conference was the establishment of the United Nations Environment Program (UNEP), which would initiate a number of global programs throughout the 70's and into the 80's. In 1984, the World Commission of Environmental Protection and Development released the now famous Brunt!and Report, named after the Norwegian Prime Minister who chaired the Commission. It proposed far reaching changes to the way we view the use of our natural resources as well as concrete, legal, financial and institutional structures to guide the process of 'sustainable development'. The concept of sustainable development became critical to the evolution of the UNCED agenda. In fact, the RIO Summit was billed as the "best chance to put the world on the path to sustainable development." The structure of the conference, which sought input from business, non government environment organizations and other national and international Interest groups, reflected the growing trend towards multilateral environmental solutions. HWBUI0005361 2. m AGENDA 21... Specific proposals and texts, which were to be presented for ratification in Rio, were first developed and debated at meetings of the Conference's Preparatory Committee (Prep Text of the Venezuelan proposals Venezuela proposed the inclusion of throe paragraphs in AGENDA 21 which make specific reference to asbestos. They were as follows: ITEM 53 b) Adopt policies and legal frameworks and procedures to identify, regulate and minimize the use of hazardous chemicals by substitution severely re stricting the user, and phasingout of the production and use, as a priority for those chemicals, which are on the prohibition lists of international conventions, in particular, asbestos materials and organohalogen compounds. f) Develop programmes including research, to replace toxic chemicals with alternative clean technologies and less hazardous substitutes, and especially such toxic chemicals for which there is reason to believe that their use may need to be restricted or banned, including ones which arc on the prohibition list of international conventions, in particular asbestos materials and organo halogen compounds. ITEMS* International organizations with active participation of governments and non-governmental organi zations should: i) Promote and develop legal instruments and mechanisms to phase out the production and use of asbestos materials, formulating programmes to substitute for them with safer alternatives. Com) which took place in the two years preceding UNCED. At the third Prep Com meeting, held in Geneva in September 1991, there was much discussion concerning the most effective approach to the use of chemicals and toxic products. At the outset, several delegations noted that the soundest approach was not to totally prohibit the use of these beneficial products, but to use them in a responsibly controlled manner in order to minimize or eliminate risks for workers and the general public. Although AGENDA 21 was not designed to deal specifically with any one chemical or mineral substance, Venezuela nonethe less proposed the inclusion of three specific references to `asbestos materials'. These references called for the ban, phase-out and replacement "of those chemicals which are on the prohibition list of international conventions, in particular asbestos materials and organo halogen compounds." Many delegates took issue with both the accuracy and the intent of the paragraphs and their inclu sion remained unresolved at the conclusion of Prep Com III. It also remained unclear why Venezuela sought to include specific mention of a ban of asbestos given the strong support from both political and scientific communities for its controlleduse. A strong Venezuelan substitute fibre industry based on its petro-chemical capacity may have been a critical factor in the process. Venezuela has a large PVC (Polyvinyl chloride) pipe industry which sees its products as a substitute for asbestos-cement pipe in water transportation and sewage systems. Interestingly enough, (see AGENDA 21 on page 3) *Beware offalse claims and irrational thinking,n top scientists warned Rio delegates More than 41$ scientists from 29 countries -- including 61 Nobel Prize winners -- launched an outspoken attack on environ mental extremists in a signed petition, which was presented to UNCED delegates during the Earth Summit. They warned delegates to ignore the `pseudoscience' which passes for truth among many environmentalists. The statement -- one of the first organized attempts by the scientific community to influence the international environmental debate -- represents the concerns of many researchers, academics, and medical practitioners, it says: "We are worried to see the emergence of an irrational ideology which opposes scientific and industrial progress and is damaging to social and economic developments." Sir Richard Doll, the Nobel Prize winning scientist who first proved the link between smoking and cancer, commented on his group's statement, saying: "We are 100 per cent behind the RIO Summit and its resolutions on global warming and the protection of species, but we think the greatest threats lo the world come from poverty, disease and overpopulation. It's only through science and industry that we can tackle these things." Linus Pauling, two time Nobel Laureate, summed up the group's approach, commenting that the needs of the environment had to be balanced against the needs of people. HWBUI0005362 3. m<& AGENDA 21... the U.S. Environmental Protection Agency admitted to the Court of Appeals during the proceedings evaluating the risks of asbestos substitutes that "vinyl chloride, used in PVC is a human carcinogen that is Position of The Asbestos Institute Items S3 b) and 0 arc based on the mistaken assumption that asbestos is on the prohibition list of one or more international conventions* Asbestos is on no such list. With existing dust control techniques, asbestos can be used with no undue risk to the health and safely Of industry workers or to the general public. This is supported by a vast body of scientific research as well as international organizations such as the DLO and the WHO. Many asbestos substitutes have known carcinogenic effects. Based on the results of animul experiments and epidemiologi cal studies, the International Agency for Research Cancer (IARC) has identified many man-made mineral fibres as Class 2B carcinogens. The potential health risks of substitutes was also one the principal reasons why the U.S. Court of Appeals rejected the EPA's ban of asbestos. Hundreds of chemicals cons titute a potential health risk if not used properly. There is no logical reason why asbestos, whose properties are well documented and for which control measures for its safe use have been well established. Should be singled out in AGENDA 21 or any other international environmental decree. especially potent during the manufacture ofPVC pipe." Given the disagreements, which existed over the Venezuelan proposals, they were identified as items requiring further discussion or negotiation and carried forward to the Fourth Prep Com meeting held in March/April 1992 in New York City. MISTAKEN ASSUMPTIONS The position of The Asbestos Institute was and is that the Venezuelan proposals were unjustified, ill-conceived and out of line with the broader objectives of AGENDA 21. The overwhelming body of scientific evidence suggests that as with many other chemical and mineral substances, given adequate control measures, asbestos can be used safely and to the benefit of society. Ironically, Venezuela, a country which has used asbestos cement successfully in its low cost housing projects, chose to ignore this evidence. Moreover, the items put forth by Venezuela were based on the mistaken assumption that asbestos is on the prohibition list of one or more international conventions. It is not on any such list As such, the Vene zuelan proposal was clearly and fundamentally flawed. In fact, the only international convention which deals specifically with asbestos is ILO Convention 162, Safety in the Use of Asbestos. Adopted by 125 participating countries in 1986, Convention 162 does not call for the ban of all types of asbestos and asbestos products, nor does any other international convention. Most industrialized countries have opted for controlled-use, and the decision of the U.S. Court of Appeals to strike down the EPA's ban rule has lent further support to this approach. These developments, as well as increasing concerns regarding the carcinogenicity of substitute fibres, underscore the need for regulatory authorities to under take comprehensive risk assess ment and cost/benefit analyses of all replacement materials and products. In summary, the position of AI was that in the case of asbestos and other risk-related fibres, the objectives of AGENDA 21 could best be achieved through a controlled-use approach rather than through an outright ban. Rather than single out asbestos, it would seem more desirable to retain a general recommendation for govern- (see AGENDA 21 on page 4) UNCED Final Position ARTICLE 19.50 b) Undertake concerted activities to reduce risks for toxic chemicals, taking into account the entire life cycle of the chemicals. These activities could encompass both regulatory and non-rcgulaiory measures, such as promotion of the use of cleaner products and technologies; emission inven tories; product labelling; use limitations; economic incentives; and the phasing out or banning of toxic chemicals that pose unreasonable and otherwise unmanageable risk to the environment or human health... c) Adopt policies and regulatory and non-regulalory measures to identify, and minimize exposure to toxic chemicals by replacing them with less toxic substitutes and ultimately phasing out the chemicals that pose unrea sonable and otherwise unman ageable risk to human health and the environment.,. HWBUI0005363 4. W *$S AGENDA 21... ments and international organizations to formulate and adopt regulations for the controlled-use of all toxic chemicals and products (includ ing asbestos and all other industrial fibres) in order to safeguard human health and environment. Toxicologists debate dangers of RCFs At the annual meeting of the Society of Toxicology held in Seattle this spring, one of the most hotly debated topics was the health risk of Refractoiy Ceramic Fibres (RCF), reported the publication Science (March *92). Toxicology is the science that deals with poisons and their effects, as well as their clinical, industrial and legal implications. The field has been paying close attention to developments in the area of man-made mineral fibres, and RCFs in particular, as mounting concerns are raised as to their safety. (see RCFs on page 6) PREP COM IV -- THE FINAL MEETING BEFORE RIO In anticipation of the Fourth Preparatory Committee meeting, AI undertook an extensive program to put forth its views concerning the Venezuelan proposals. With the assistance of diplomatic and trade delegations of both Quebec and Canada, AI travelled to Venezuela and Columbia to further discuss the validity of its controlled-use approach; representatives met with the UN initiated Council for Sustainable Development (a group of 48 international business leaders headed by Swiss industrialist Stephan Schmidheiny); and in Geneva, AI met with key UNCED personnel. In the days leading up to Prep Com IV in New York, the effort was intensified and numerous delegates were briefed on the issue. As a result of the intervention of AI and delega tions from Quebec, Canada, Brazil, India, Zimbabwe and other countries, any specific reference to asbestos was dropped from AGENDA 21. Those sections of AGENDA 21 dealing with the management of toxic materials remained general statements on the need to carefully study, manage and control potential health risks resulting from the use of chemicals. In search of a zero risk society? "It is imperative that our national health policy be reevaluated to recognize that moneys spent to reduce or eliminate exposure to a perceived health hazard should be proportioned to the risk associated to that hazardaccording to Dr. Malcom Ross, Research Mineralogist with the U.S. Geological Survey. In a paper presented at the 28th Forum on the Geology of Industrial Minerals, Dr. Ross maintains that the increasingly stringent Federal regulations promulgated in the United Sates are based on a health policy that appears to demand a risk-free living environment. The prevailing cancer dogma in the U.S. espouses the `no threshold' theory of cancer induction. Proponents of this theory believe that since no one knows the minimum amount of a carcinogen required to initiate the growth of a tumor, it must be assumed that any amount of a carcinogen is unsafe. Thus the public is led to believe that exposure to just one molecule of a chemical carcinogen can cause cancer. Regarding exposure to asbestos and other mineral fibres, this paradigm becomes `one fibre kills'. "What the public has not been told," commented Dr. Ross, "is that simply living on Earth exposes us to innumerable naturally occuring carcinogens." Probably one half of all minerals and chemicals, when tested in animals at very high doses will produce tumors. Naturally occurring chemical carcinogens at concentrations of 50,000 parts per billion (ppb) are found in such common foods as apples, strawberries, cauliflower, cabbage etc. They are often part of natural defence systems of these edible plants. Dr. Ross believes that millions of dollars are being wasted in futile efforts to reduce risks levels which are already immeasurably low. For example, the city of San Jose, California, has put a hold on an extension of its mass transit line because it would require cutting through a hill composed of serpentine rock, a commonly occurring rock containing small amounts of chrysotile asbestos. If serpentine rock is considered toxic, thousands of square miles of land in the U.S. might be placed off limits for any kind of development. Dr. Ross goes on to cite a number of other examples which are representative of the great lengths and expense which policy makers, due to pressure from interest groups, are willing to go in order to create a zero risk society. "The 'no thresdhhold dogma for cancer induction that is being foisted on the American public is generating a national crisis that could seriously damage our economy," concludes Dr. Ross. HWBUI0005364 5. Predicted rate of asbestos linked disease has not materialized: experts say risk estimates were not realistic "The huge number of asbestos- evidence shows that the actual mating asbestos-related cancer related cancer cases once forecast figure is even lower than this. A rates. The EPA based its 1986 by the [US] government and its study conducted by P.E. ruling to ban and phase out almost advisors have not materialized, Enterline of the University of all uses of asbestos on estimates, and experts say the dire Pittsburgh concludes that only which purported that eliminating predictions of the 1970's were 1% of cancers are related to past asbestos would `save' more than overblown", reports the Journal asbestos exposure -- almost 20 one thousand lives over 15 years. of the National Cancer Institute times less than the original HEW In 1988, this figure was revised in its April 15th edition. estimates. to 315.8 cases of cancer, and again in 1989 to 148-202. In 1978, Joseph Califano, secretary of the U.S. Department of Health Education and Welfare (HEW) predicted, based on estimates provided by Dr. Irving Selikoff and others, that about 17% of all cancers in Marvin Schneiderman, Ph.D, one of the authors of a report upon which the 1978 estimates were based, now be EPA'S ESTIMATES OF CANCER CASES AVOIDED BY ASBESTOS BAN IN THE FUTURE PERIOD OF 13-15 YEARS Typs of products 1986 1988 1989 the future would be caused by lieves that the Vinyl-asbestos floor tiles 468 0 0 asbestos -- an annual total of overestima Friction Droducts 386 282 99.4-143.7 between 58,000 and 75,000 tion resulted Asbestos-cement pipes 82 6 2.1 - 4.4 asbestos-related cancer deaths from applying Asbestos-cement plates 31 0.9 0.7-1.5 Gaskets 0 14 6.7 - 42.5 were anticipated. Selikoffs data Other 33 12.9 39.1 - 9.9 on heavily ex Scientists have believed for posed workers Total 1 000 315.8 148 - 202 more than a decade that these to a much larger projections were much too high. population whose exposures were In light of the ruling by the At a 1981 conference, cancer generally much briefer. "We made U.S. Court of Appeals, which epidemiologists rejected the the inappropriate assumption overturned the EPA's asbestos government estimates believing that short-term exposures were ban, serious doubts remain as to that they were more than 10 just as carcinogenic and deadly the accuracy of even the latest times too high. More recent as long-term exposures revised risk estimates. There are Schneiderman two principal reasons why these said: "Now it estimates are being questioned. ESTIMATES OF PERCENTAGE OF LUNG CANCER DEATHS RELATED TO ASBESTOS IN THE USA looks as if you have to have Firstly, they fail to take into account the carcinogenicity of fairly con substitutes, and secondly, many tinuous expo experts are concerned that the sure to cause risk estimates are based on the worst faulty assumptions. Among the effects." skeptics is Philip Enterline, Ph.D., of the University of Pittsburgh School of Public FLAWED EPA Health who recalls his ESTIMATES incredulous reaction to inflated LED TO BAN estimates of future asbestos- RULING related cancers. "If it were true," 1. Nation* Canoar ImHute (Eslmct** Papar) [75,000 cancar daalWyaar) 2. National Canoar Inaftuti (Ealmatas Papar) [56,000 cancer deatw/yaar] 3. I. Saikoff (OSHA Hearing*, June 1976) [50,000 cancer deatha/yaw] 4. Ncholaon at ai. (Bradbury Report No. 9, Cold Spring Harbor Laboratory. 1081) 110,000 daatha/yaarl 5. NictoUon at ai. (Branbury Report No. 9, Cold Spring Harbor Laboratory, 1961) (8,500 deaths/year] 6. Hogan and Hoel (Ri* Arvtfyatt, Vol. 1, pp. 67-7%, 1961) 7. EntarUrw (Bradbury Report No. 9, Cold Spring Barbor Laboratory, 1961) HEW was not alone in overesti Dr. Enterline said, "it would have been the best news I've ever heard. If we could eliminate 17% (see EXPERTS on page 6) If you have any comments, suggestions ot ideas for future stories or special reports, we would be delighted to hear from you. If you would like to be on our mailing list, you can reach us at: The Asbestos Institute, c/o Editor, 1130 Sherbrooke Street West, Suite 410, Montreal, Quebec, Canada H3A 2M8, telephone: (514) 844-3956, fax: (514)844-1381. This newsletter is also published in French. HWBUI0005365 EXPERTS... RCF8.... of all cancers just like that, it In the mid-1980's, researchers would be marvelous. But it was found that rats injected with RCFs too good to be true." developed lung fibrosis, lung cancer and mesothelioma. Then in In its final rule, the EPA 1988, a team of toxicologists attributed almost 200 projected headed by Richard Mast, chief cases of cancer to exposure to toxicologist at the Carborundum friction materials. With respect Co., began a study in which rats to friction materials, the Court of and hamsters inhaled aerosolized Appeals noted that the EPA had RCFs. The research team found "failed to evaluate the toxicity of that animals that inhaled RCFs likely brake substitutes." It developed far more lung tumors mentioned specifically that the than control animals did. In EPA had "overlooked credible addition, mesothelioma rates contentions that substitute were higher than those of most 'products might actually increase forms of asbestos fibres. fatalities7* ~~ Discussions centered around Scientists are also beginning to question how the EPA deter the generalizability of the data, the existence of a threshold level mined that almost 200 people of exposure necessary to produce would develop cancer due to disease and the potential for asbestos in friction materials. regulatory responses by the EPA. Professor F. Valic, consultant to the WHO's International Pro In general, there was gramme on Chemical Safety agreement that the overall risk (IPCS), believes that the basic to the population is low because premise, which extrapolated RCFs are used in industrial incidents of mortality in industry equipment rather than in public workers exposed to amphiboles buildings or homes, and or to amphiboles and chrysotile therefore few people outside the to a general population which industry are exposed to comes into contact with very low dangerous levels of them. levels of chrysotile fibres, is seriously flawed. EPA scientist Jim Willis nonetheless believes that "there In a recent paper presented are a fair number of workers at the International Colloquium who manufacture and use RCFs. on Dust Measurement Techniques We've determined that RCFs and Strategy, Prof. Valic goes on present or will present a to say that "these [EPA's] risk significant [cancer] risk." A assessments were obtained using decision from EPA on how it a geometric mean of risks derived plans to proceed is expected from 11 studies in different within a few months. industries of which the friction materials industry is only one". The report goes on to cite a number of highly reputable studies, which found little or no excess lung cancer amongst U.S. to standardize risk assessment procedures brake industry workers. On the basis of this and other credible evidence, an IPCS/WHO working According to inside sources, the group concluded that "provided White House is expected to issue good work practices are followed an executive order designed to and no amphibole"fibres are used, standardize risk assessment 'detectable risks in vehicle procedures. The new review pro maintenance and repair workers cedure, under the auspices of the are not expected. " Office of Science and Technology Policy (OSTP), would require regulatory agencies to base their health and safety assessments on realistic estimations of risk -- as opposed to worst case hazards. "Science is subordinated in the decision-making process", according to Thorne Auchter, director of the Institute for Regulatory Policy and former OSHA administrator. "This (new order) would let scientists have their day in the regulatory process." Auchter also believes that contrary to prevailing criticism, the regulatory process is manipulated less by `big business' interests than by federal regulators and policy makers. "An effort to standardize the risk assessment process would eliminate the opportunity for some 'manipulation'," he said. Given that those sectors currently being regulated did not undergo the same risk assessment review procedure, the new executive order would provide a process in which agencies could be petitioned by the public to revise risk assessment and risk manage ment decisions on the basis of new scientific information. # Source: Occupational Safety & Health Reporter, 6-3-92 It is with great sorrow that we announce the death of JeanPierre Chevalier-Bultel, the Institute's Director of Research and Development and International Relations. Mr. Ohevelier-Bultel, who has been with The Asbestos Institute since 1986, is survived by his wife Franfoise and three children. Our deepest sympathy goes out to his family and friends. 3_. THE ASBESTOS INSTITUTE 1130 Sherbrooke Street West Suite 410, Montreal (Quebec) Canada H3A 2M8 Telephone: (514) 844-3956 Telex: 055-60565 (1NSTAM) Telecopier: (514) 844-1381 HWBUI0005366