Backgrounder On The Risk Management Of Chrysotile
(Prepared by Natural Resources Canada)
Although industrial development contributes to the well being of our society, it can also lead us to use many hazardous products every day. In order to be able to take advantage of the benefits of these products, while avoiding their harmful effects, we have adopted standards and developed technologies and work methods that constitute what is known as the controlled-use approach. When the risks associated with a product cannot be controlled, this approach calls for its use to be discontinued; products containing the friable form of chrysotile were banned, in part, for this reason. However, the risks associated with chrysotile and its non-friable products, such as those made from chrysotile cement, can be controlled. These products can therefore be used in a safe manner. The Canadian government has relied on scientific data in adopting this position with regard to chrysotile as well as all minerals and metals in order to ensure the safety of workers and the population in general. The following is a brief review of the background of this approach.
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Chrysotile in the environment
Chrysotile, a naturally occurring substance, is omnipresent in the environment. In fact it is present in two thirds of the rocks that make-up the earth’s crust. As a result of bedrock erosion, by way of water and wind action that liberate chrysotile fibers from the rock, we are environmentally exposed to chrysotile fibers. Irrespective of where we are on earth we all breath an average of 10 000 to 15 000 chrysotile fibers every day. Potable water contains an average of 200 000 to 2 million chrysotile fibers per liter, and can reach up to 170 million fibers per liter in chrysotile producing areas in Quebec.
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Development of Canada’s controlled-use approach on Asbestos
Commercial production of chrysotile began in Canada in the second half of the 19th century. The Jeffrey mine, an industry landmark located in Asbestos, Quebec, has been a source of chrysotile since 1878. Up until its glory days in the 1970’s all Canadian chrysotile producing companies were owned by foreign investors who favoured the mining of chrysotile fibres and its export to their countries of origin namely the United States, the United Kingdom, Belgium and France where chrysotile based products were manufactured. Control of the industry was surrendered to Canadian interests when the controversy related to the harmful effects of asbestos on human health surfaced.
The lessons learned over the years have been difficult ones. Canadian workers know from experience the hazards associated with chrysotile. They realized that prolonged exposure to high doses of chrysotile dust was related to a high risk of developing certain types of lung disease. As early as the 1920s, indications began to appear with regard to the incidence of disease associated with exposure. However, science was not as advanced as it is today, the union culture was developing gradually, and government social agencies were non-existent. After many struggles, including the major strikes of 1949 and 1975, chrysotile workers succeeded in achieving recognition of their right to working conditions that do not endanger their lives. The working conditions enjoyed today are the result of those efforts.
It was not until the end of the 1970s and the early 1980s that the controversy surrounding the health effects of asbestos began to grow in response to a rise in the number of deaths related to exposure and to a demonstrated increase in cancer risk associated with prolonged exposure to high doses of asbestos dust in the workplace. The situation was primarily the result of the widespread uncontrolled use of asbestos during and after the Second World War. During the War, asbestos was sprayed onto the walls of warships to protect them from fire, and used in making gas masks. During the postwar period, asbestos was widely used in Europe in the rebuilding of infrastructures. Asbestos spraying provided thermal and acoustic insulation for buildings and protected metal structures against fire; asbestos was also used in the manufacture of asbestos-cement products. Because of the latency period between the time of exposure to asbestos and the onset of disease (20-35 years), the increase in the number of deaths recorded in the 1970s and 1980s is related to intensification of asbestos use in the 1940s and 1950s.
In order to address this social crisis, a federal-provincial working group (FPWG) was established in 1979 with a mandate to develop a consistent, science-based approach to regulating asbestos in Canada. In 1982, the group published a document entitled a "Current Approach to the Regulation of Asbestos in Canada," which was approved by the federal departments concerned and endorsed by the relevant departments in every province.
Essentially, this document recommended a controlled-use approach to the regulation of asbestos, which is the position that was adopted by Canada. According to this approach, through the implementation of appropriate regulations aimed at rigorously controlling exposure, the risks associated with exposure to chrysotile during extraction, crushing, transportation and handling and in manufacturing processes can be reduced to acceptable levels (i.e. levels at which no increased risk exists of contracting lung diseases). Conversely, applications involving exposure that cannot be controlled in an appropriate manner should be prohibited. One such application, the spraying of asbestos for insulation purposes or to create firewalls in buildings or boat hulls, was voluntarily discontinued by the Canadian industry in the mid 1970s. It was not officially prohibited until 1988 under the terms of the Hazardous Products Act. Given that living is inherently dangerous, it is important to minimize all risks, while bearing in mind that they can never be completely eliminated.
The controlled-use approach was developed after an extensive review of scientific data on the potential health effects of exposure to asbestos. By twenty years ago, an impressive body of information had already been compiled on asbestos. Its effect on health was almost as well understood as it is today. The approach suggested by the FPWG was based, in part, on the work of the Ontario Royal Commission on Matters of Health and Safety Arising from the Use of Asbestos (ORCA), which conducted a study from 1980 to 1984 to confirm the link between lung disease and work. Based on the sworn testimony of respected international scientists who were examined and cross-examined by industry, union and government representatives, the ORCA conducted what is still considered to be the most extensive and authoritative study on asbestos. Its conclusions brought out the need to distinguish between serpentine (chrysotile) and amphibole (crocidolite, amosite, tremolite, actinolite and anthophyllite) fibres, and to identify fibre length. Like the FPWG, it recommended adoption of the controlled-use approach for chrysotile.
An ORCA witness, Professor Corbett McDonald, directed one of the most well-known epidemiological studies of lung-cancer risk among chrysotile workers. By studying some 11,000 mine workers from Thetford Mines over a 14-year period, researchers were able to identify a positive correlation between risk and increased duration and level of exposure. However, they determined that the lung-cancer risk among chrysotile workers continuously exposed to one chrysotile fibre per cubic centimetre of air (1 f/cc) is equivalent to the risk incurred by a person smoking two cigarettes a week. With few exceptions, chrysotile product industries throughout the world now comply with this exposure standard or even a 0.5 f/cc standard. It should be noted, moreover, that levels of exposure to chrysotile dust outside the workplace never reach or come close to 1 f/cc. Ambient air measurements indicate that chrysotile levels are generally 1,000 times lower than this workplace level.
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Canada’s Safe-Use Principle
The controlled-use approach was further expanded to the use of all minerals and metals in 1996 when the Government of Canada adopted the safe-use principle in its Minerals and Metals Policy. The Safe-Use Principle, which is similar to the controlled-use approach, covers assessment and management of the risk associated with the use of minerals and metals in terms of impacts on the health of users and on the environment. Canada adopted the "Safe-Use" principle towards asbestos, to address the health concerns associated with all types of asbestos fibers throughout their life cycle, from the mining, the manufacturing of products and their use, to the waste management. It is essentially a strict risk management approach to ensure that people are not exposed to significant levels of asbestos fibers, particularly amphibole fibers. Amphibole asbestos use in Canada is essentially negligible in comparison to chrysotile. Although, chrysotile is considered to be a less potent carcinogen when compared to the amphiboles, it is still considered a carcinogen, therefore its use is predominantly restricted to products with non-friable fibers, or fibers trapped in a solid matrix. The Safe-Use Principle guides product stewardship programs, monitoring, and product based regulation in Canada.
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The Asbestos Institute and the Promotion of the Safe Use of Chrysotile
The Asbestos Institute (AI) was created in 1984 as a tri-partite (government-industry-labour) organization supported by the federal and Quebec governments as well as by the Canadian chrysotile industry. Its mandate is to defend and promote the safe use of chrysotile fibres and associated products in Canada and throughout the world. Its formal objectives are to:
- Promote the adoption and application of appropriate prevention and control measures, regulations, standards, work practices and techniques for the safe use of chrysotile.
- Take part in international conferences by offering relevant documentation, advice, or technical, medical and scientific training to chrysotile producers and users of chrysotile in other countries as well as to industrial health specialists (note: to date, the AI has organized more than 120 missions of this nature to 60 countries).
- Gather and disseminate medical, scientific and technical data about asbestos and substitute fibers.
- Inform and advise the general public, the media, lawmakers, workers, as well as special interest groups on the potential risks related to respirable fibers.
Since the inception of the AI in 1984, contributions from all partners have totaled $57 million. These contributions have enabled the:
- Development of communications material and the organization of information seminars;
- Inspection of factories that use chrysotile to evaluate the efficiency of on-site measures to prevent and control dust;
- Development and delivery of training programs for specialists on industrial ventilation and dust control, and in air sampling and fiber counting; and
- Organization of seminars by trade unions (under the aegis of the AI) to teach best practices to workers in industries that use chrysotile.
The AI is managed by a Board of Directors comprised of industry, labor and government representatives. The Board establishes policies and approves the program and the budget. The AI relies on the cooperation of a large network of medical, scientific, legal and technical experts and advisors, who provide services upon request.
The AI also provides technical and financial aid for creation of national industry associations in other countries (12 associations in 12 countries). These associations distribute health and safety information to their members, organize training seminars, coordinate dust-monitoring activities with the Asbestos International Association (AIA), which is located in Montreal, coordinate government-industry relations and monitor developments.
Training is organized in cooperation with national governments and may include participation from the International Labor Organization (ILO). They are oriented towards promoting the controlled use of chrysotile. For this purpose the AI and AIA have developed manuals on safe working methods (examples in attachment) and equipment, and have organized training courses for industrial health specialists and workers on air monitoring and dust control techniques. These training courses were predominantly carried out in developing countries.
The AI publishes quarterly newsletters, as well as numerous documents and videos on health, safety and asbestos products. Other publications include a manual of prevention and control measures for industry and a biomedical data bank which houses summaries of more than 8,000 scientific papers.
Overall, it is doubtful that any other hazardous substance exported to developing countries has received the level of attention to training in health and safety than Canada has provided for chrysotile.
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The International Chrysotile Industry’s Responsible Use Policy
On March 3, 1997, the Canadian Government signed a memorandum of understanding (MOU) on the responsible use of chrysotile with the two Canadian chrysotile producing companies to formalize a Canadian government / industry cooperation for the promotion and implementation of the international chrysotile industry’s responsible-use policy. The signature of this agreement followed the signature in 1995-1996 of a responsible use policy MOU by producers from Canada, Brazil, Russia, South Africa, Swaziland and Zimbabwe. This responsible-use policy is a voluntary undertaking by international producers and exporters of chrysotile. It is based on the recognition and acceptance of the principles outlined in the International Labor Organization (ILO) Convention 162, Asbestos Convention, 1986, which Canada ratified on June 16, 1988, and the ILO Code of Practice, entitled Safety in the Use of Asbestos, adopted by the ILO in 1984.
The objective of the responsible-use policy is to supply chrysotile only to those companies who are in compliance or which have provided formal written commitment and action plans to bring their operations into compliance with national regulations. However, since signatories of the industry MOU are not expected to act as inspectors, the responsibility for enforcing regulations fall upon each client’s government.
The federal government / industry MOU does not engage the federal government in additional regulations, enforcement mechanisms or expenditures beyond those already in place or planned. It, however, commits the Government to facilitate the introduction and implementation of the responsible-use policy in chrysotile-consuming countries to help ensure that employees in all client countries have a safe working environment. This MOU signaled that the Canadian government will work vigorously with companies and countries to promote the safe-use of chrysotile internationally. Canada is especially active in developing countries with training programs and, where required, assists the development of appropriate regulations and policies for safe-use.
According to the Canadian government’s responsible-use agreement with the industry, the latter is expected to work with its clients to ensure appropriate regulations are in place at the plants. If the client company does not cooperate to ensure safe-use, the chrysotile supplier is expected to notify the Canadian government of the situation and the latter to report the problem to the appropriate governmental agency in that country. The Canadian government’s role is then to assist the recipient country to either develop proper legislation if it’s missing or to help ensure the client company complies to the regulations. If after these efforts the company does not comply, its supplies are cut. The Canadian government has been active in assisting a number of countries adopt appropriate regulations. These include: Taiwan, Chile, Morocco, Caribbean countries, Mali, Algeria, etc.
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Canadian laws and regulations to ensure the safe use of chrysotile
Canadian laws and regulations to ensure safety in the use of chrysotile apply either to the country as a whole or to provinces and territories since the latter have responsibility for the workplace as well as some environmental and health matters. At the federal level, the laws and regulations relating to asbestos are:
- The Canada Labor Code (managed by Human Resources and Development Canada), which applies to federal government employees. It defines the occupational exposure limit to asbestos (1.0 f/cm3 for chrysotile, 0.1 f/cm3 for amosite, and 0.1 f/cm3 for crocidolite). The levels of exposure recognize the difference in the risks associated with each asbestos fiber and are consistent with the recommendation of the report of a group of experts convened by the World Health Organization in 1989;
- The Hazardous Products Act (managed by Health Canada), which is designed to protect all Canadians, lists certain products or uses that are prohibited such as sprayed asbestos used for insulation purposes, and certain textiles;
- The Canadian Environmental Protection Act, 1999 - Asbestos Mines and Mills Release Regulations (managed by Environment Canada), which regulates the release of asbestos fibers (limit of 2 f/cm3) into the atmosphere from the producing facilities to protect both the people and the environment. These regulations were enacted in 1977 as part of the Clean Air Act. In 1990, these regulations were incorporated into the new Canadian Environmental Protection Act;
- The Transportation of Dangerous Goods Act (managed by Transport Canada), which applies to the handling (packaging), the offer for transport, the transport and importation of dangerous goods;
- The Workplace Hazardous Materials Information System (WHMIS) (also managed by Health Canada) covers the labeling of hazardous materials and specifies requirements to ensure that workers receive appropriate information and training if called upon to work with or handle hazardous substances and products. This system was developed in cooperation with all social partners during the period 1982-1985. It was adopted in 1987 under the Hazardous Products Act in response to the need for workers and employers to be informed of the hazards of materials used in Canadian workplaces.
Under WHMIS, asbestos is a Class D2 substance - "poisonous and infectious material - materials causing other toxic effects" - a chronic toxic material, not an acute toxic substance. Consequently, all bags of asbestos fiber and all products containing asbestos must bear the toxic T label and appropriate warning phrases. Note that all other fibers classified by IARC as Class 2a or 2b must also bear the toxic T label.
Instead of describing or providing an exhaustive list of all 10 provincial and territories laws and regulations pertaining to asbestos and asbestos containing products, a list of those applying to the province of Quebec are provided as an example. Other provinces and territories have similar laws and regulations in place to ensure the protection of its workers and its population.
Quebec laws and regulations are designed to ensure the safety of workers, of the population and of the environment during the production, manufacturing and use of chrysotile products on construction sites. The Quebec laws and regulations are:
- Environment Quality Act
- Regulation respecting the Quality of the Atmosphere which regulates emissions from chrysotile mines and mills.
- Regulation respecting Solid Wastes.
- Occupational Health and Safety Act
- Safety Code for Construction Site, which applies to any construction site where work liable to produce asbestos dust emission can occur.
- Regulation respecting the quality of the work environment. It governs every aspect of the work environment to ensure its quality, and to safeguard the lives and health of the workers.
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Other controls fostering the safe use of chrysotile in consuming countries
International Labor Organization Convention 162 on Safety in the Use of Asbestos
Adopted on June 24, 1986, and entered into force on June 16, 1989, the International Labor Organization (ILO) Convention 162 on Safety in the use of Asbestos has since its adoption been ratified by 27 countries, including Canada (1988). This Convention sets out the minimum requirements for the protection of workers using asbestos. The minimum requirements support the controlled-use approach taken by Canada.
The Convention aims to prevent occupational hazards due to asbestos and applies to all activities involving the exposure of workers to asbestos in the course of work. Under the Convention, national laws or regulations are to prescribe the measures to be taken for the prevention and control of, and the protection of workers against, health hazards due to occupational exposure to asbestos. The employer is responsible for compliance, and enforcement is ensured by inspection. Exclusions, exemptions and revisions are regulated by the Convention. It also enumerates various detailed measures for protection and prevention, as well as for the monitoring of the workplace and of the workers’ health.
International Organization for Standardization; Code of practice
In preparation to the development of ILO Convention 162, the International Organization for Standardization (ISO) had already developed in 1984, for the construction industry, a code of practices (ISO-7337: Asbestos reinforced cement products - Guidelines for on-site work practices) to ensure safety in the use of asbestos based products.
World Health Organization; Definition of "acceptable exposure level"
To address the issue of "acceptable" exposure level, a World Health Organization (WHO) consultation group made up of 30 renowned epidemiologists, scientists and medical doctors was convened in 1989 to develop recommendations on occupational exposure limits for asbestos. The group’s objective was to establish a permissible occupational exposure limit for chrysotile in order to facilitate the regulation of this substance, particularly in developing countries. After considering the latest evidence on asbestos and health, the group endorsed a maximum permissible exposure limit of 2 fibers per milliliter of air with efforts to lower this level to 1 fiber per milliliter of air. All participants agreed that, at currently attainable low occupational exposure levels, any health risk to workers would be very small.
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