8.0 - COMMISSION 3: THE REGULATORY FRAMEWORK

8.1 - Introduction
8.2 - Findings

8.2.1 - Local Issues
8.2.2. - Barriers to Developing Claimants

8.2.2.1 - Medical Obstacles
8.2.2.2 - The Effects of Corruption
8.2.2.3 - Touting and Statutes of Limitation
8.2.2.4 - Geographic Isolation

8.2.3 - Needed Infrastructure for a Large-Scale Suit Against Industry

8.2.3.1 - Presence of Strong Activists
8.2.3.2 - Record-Keeping
8.2.3.3 - Transportation

8.2.4 - Grounds to Sue Under South Africa Law

8.2.4.1 - Ex-Miners
8.2.4.2 - Exposure to the Industrially Contaminated Environment
8.2.4.3 - Women and Children Workers
8.2.4.4 - Time Restraints on Bringing a Claim

8.3 - Conclusion


8.0 -COMMISSION 3: THE REGULATORY FRAMEWORK

"Is there any hope?" - Widow of Ex-miner Living in Batlharos

8.1 Introduction
Beyond the needs for health care, rehabilitation, and education lies the possibility to litigate against companies who compromised the health and well-being of workers, their families, and villages contaminated by asbestos. Litigation constitutes a crucial dimension through which to approach compensation for those affected by ARDs. While asbestos litigation is a frequently discussed topic in South Africa, few groups other than the English firm Leigh Day & Co., which is involved in the lawsuit against Cape Plc., have actually undertaken legal action against an asbestos mining company. The Cape Plc. Case remains primarily a UK endeavour, involving a British legal group seeking damages in Britain against a British company that had South African subsidiaries. Legal action against a South African parent company within South Africa has not yet been undertaken in any systematic fashion.

8.2 Findings
The seeds of a legal suit on South African soil, however, are germinating in the town of Kuruman, where several attorneys are exploring possibilities for litigation against the former asbestos mining company, Gefco. To assist in examining options for legal action, two post-graduate students worked in collaboration with a South African attorney from Nelspruit to work with plaintiffs for a legal test case. In this section, we examine local issues, the obstacles and infrastructure needed to develop claimants in Kuruman and the surrounding areas, and outline the grounds to sue under South African law.

8.2.1 Local issues
Our initial contact was with Kuruman Asbestos Sufferers (KAS), an organisation created by a local businessman suffering from mesothelioma. KAS aimed to track the incidence and prevalence of the disease in the region, create a database, and advocate for the fulfilment of compensation claims. Recently, the group recruited an office manager from the CPAA who was very knowledgeable about the MBOD and the Compensation Commission. This consolidation has the potential to provide more structure and expertise for KAS, a desperately needed local headquarters for CPAA, and some protection against corruption. Although fragile, the merger appears to be having some success.

Our interviews with potential claimants were conducted in the KAS/CPAA office in Kuruman. KAS/CPAA contacted people with mesothelioma as well as the widows of ex-miners with the disease who had recently died. Advertisements were placed in the local paper, asking people suffering from, or affected by, mesothelioma to speak with us. The law prohibits any more in-depth recruiting of potential claimants. Our interviews emphasised work history, exposure to dust, knowledge about the dangers of asbestos, earnings and compensation, and history of illness.

We interviewed potential claimants twice a week for a period of three weeks, speaking with approximately twenty people suffering from, or affected by, mesothelioma; the majority of people with whom we spoke were widows of ex-miners. However, as word of our presence in the office spread throughout the region, an increasing number of men and women who had been exposed through the contamination of their environment by asbestos asked to speak with us.

8.2.2 Barriers to Developing Claimants

8.2.2.1 Medical Obstacles

Histological diagnosis
One of the first barriers to litigation is that many sufferers of mesothelioma do not get a histological diagnosis. (See Section 7.1.2.1) As mentioned earlier in this report, this is due to an overall lack of understanding on the part of doctors, ARD sufferers and their families, and those involved in the compensation process about the importance of proper diagnoses. Thus many doctors only characterise their patients clinically, failing to refer them to hospitals, such as Kimberley, Klerksdorp, and/or Tshepong, where histological diagnoses can be made. One doctor we spoke with saw herself as helping make the patient as comfortable as possible and thus did not encourage a long and often expensive trip for her weaker patients. Even when doctors did make referrals, the actual trip to Kimberley, Klerskdorp, or Tshepong was unlikely for reasons explained previously. Of key importance is that few doctors communicate (or know) the importance of completing such a trip and thus their patients, with few resources, often do not go, without realising what they might be forfeiting with such a decision.

Although there is a "flying team" of specialists from Kimberley who travel to Kuruman to treat and diagnose mesothelioma cases, the irregularity of their visits is an additional problem. The experience of one man we interviewed is telling. Upon his arrival at the clinic, after months of waiting to see the specialists, he was told that the specialists would not be visiting that day and that he would have to wait another month.

Other diseases
The prevalence of TB in the Kuruman region also indirectly contributes to delays in or failures to the proper diagnosis of mesothelioma necessary for successful litigation. TB often obscures mesothelioma clinically. If a patient complains of a cough or a tight chest, his sputum is immediately tested for TB. If that patient tests positive, he is given antibiotics and there is no further investigation of his symptoms until the course of antibiotics is completed. This could delay the diagnosis and treatment of mesothelioma for up to six months. In addition, practitioners view TB as a greater problem than ARDs in the communities they serve. One doctor told us that TB and HIV/AIDS consumed all her energy. Although she would like to learn more, she has neither the resources nor the time to become more educated about ARDs. Finally, many doctors do not encourage post-mortems for labourers of "risk work", even though the MBOD specifically directs them to do so. One doctor admitted unofficially that post-mortems are not performed on ex-miners in her hospital. Even when doctors do ask about post-mortems, few families consent.

8.2.2.2 The Effects of Corruption
As mentioned previously, corruption is a serious problem in communities burdened by ARDs. This has justifiably bred profound mistrust of outsiders involved in asbestos compensation, research, or litigation. Corruption exists at virtually every level of the compensation system. Informal compensation brokers, referred to as "sharks," require between 30-50% of a compensation payment for their facilitation of quick results. While some do facilitate the process, others do not. One official from a local hospital that we interviewed lamented that many people pay sharks to fill out their forms, even though there is a centre dedicated to helping ARD sufferers complete forms free of charge at each stage of the process.

Other sharks trick people into thinking that they have applied for compensation by filling out a few bogus forms and photocopying them. Soon after our arrival in Kuruman, a person was arrested and charged with fraud after months of promising people that they would be compensated within two weeks, for a fee of R75-85. Weeks later, people informed us that yet another individual was continuing to charge people to complete forms.

In response to such blatant exploitation of ex-miners and their families, community activists advised residents of one village not to speak with unannounced outsiders about the asbestos problem. Even those who are not told to remain quiet are sceptical about unfamiliar people interested in the issue of asbestos. This creates serious problems when trying to recruit potential claimants for a legal case. Many people worry about fees and charges and prefer not to become wrapped up in another ill-defined business transaction around their illness. Although it is difficult to prove in a definitive way, we are strongly inclined to believe that scepticism and misunderstandings about compensation, largely due to corruption, affected our ability to interview a wide-range of mesothelioma sufferers. (See Section 7.2.2.1)

8.2.2.3 Touting and Statutes of Limitation
In addition to medical barriers and corruption, several legal requirements had a significant impact on our ability to recruit potential claimants. First, South African ethical guidelines against touting prevented us from actively seeking out people with mesothelioma. Standards opposed to "ambulance chasing" mandate that ethically one cannot directly approach a potential claimant and offer legal representation. These codes are designed to protect the professional character and good repute of the legal profession. Furthermore, statutes of limitation, as located in the Prescription Act, set out periods of prescription of various rights. The statute of limitations for personal injury claims is three years. Thus anyone diagnosed with mesothelioma prior to 1998 is not eligible to be included in a legal case. Since most victims of mesothelioma die within 18 months, recruiting live or recently deceased clients constituted an enormous challenge.

8.2.2.4 Geographic Isolation
Finally, the geographic isolation of many areas affected by mesothelioma severely affected our ability to find potential claimants. Difficulties travelling on unpaved roads as well as limited and costly transportation prevents many in outlying areas from journeying into Kuruman regularly and thus from obtaining information about asbestos, ARDs, compensation, and litigation. Many of those with ARDs continue to be unaware not only of their rights to compensation but of the causes of their illness and the possibilities for litigation as well.

8.2.3 Needed Infrastructure for a Large-Scale Suit Against Industry

8.2.3.1 Presence of Strong Community Activists
Community advocacy is desperately needed for successful litigation. Established groups such as CPAA have been long-time supporters of ex-miners and their families and work to educate ARD sufferers on the necessities of proper diagnoses and their entitlements to compensation. They also track current claims at the MBOD and the Compensation Commission. Community groups are also important in advocating for speedier responses to compensation requests and to push for better medical services, which cater to the specific needs of ex-miners, their families, and those environmentally exposed to asbestos.

If well established at the grassroots level, such local groups can also help to defuse potentially explosive and debilitating community politics by uniting stakeholders into a single movement. Community advocates can combat corruption and fraud, rendering such violations ineffective. Through education and advocacy, such groups may also battle the harmful effects of geographic isolation by advocating for tarred roads.

In addition to fostering a community informed about the various aspects of ARDs, community groups also serve another important function: to sustain those sick with mesothelioma while the lengthy process of litigation unfolds. As most legal action takes years, groups such as CPAA are essential to help people obtain compensation in the short-term and alleviate hardship while longer-term action is taken.

Finally, community activists can aid lawyers from other areas of the country in understanding past issues of concern and importance, current community dynamics, and much-needed cultural sensitivity. Since activists know many of those affected by ARDs, they can contact potential plaintiffs and help lawyers avoid touting. An office for such a group might also provide a base from which lawyers can work. It seems almost too obvious to state, but the resources for a legal case include, but are not limited to, phone cards, a photocopier, word processing, internet access, and a law library.

8.2.3.2 Record-Keeping
Written accounts of work and medical histories as well as personal identification are essential in the development of a legal case. Although Gefco charges ex-workers R25 for a copy of their work histories, more than most in the Kuruman area can afford, work records are available for former employees and their families to prove tenure of service (as the Mines and Works Act of 1956 stipulates that records must be kept for 40 years). However, it is the responsibility of those suffering from ARDs and their families to preserve the medical documents, characterising illness for a legal case. It is the responsibility of family members of the deceased to keep identification records for proof. To facilitate the preservation of such documents, people need to be educated about the importance of medical identification and work histories. In addition, since the cost of obtaining work histories from Gefco is higher than most can afford, a legal case must be equipped with resources to reimburse people the required R25.

8.2.3.3 Transportation
Transportation continues to be major obstacle for recruiting potential claimants. Since many cannot travel to town centres such as Kuruman due to a lack of local infrastructure, it is important for those developing plaintiffs to have vehicles in which to travel to villages with trusted members of the community. Since transportation costs can often be high, it is important to reimburse ARD sufferers and their families for their transportation costs.

Although developing strong claimants is a challenging endeavour, the above-mentioned components comprise some of the most basic resources needed to launch a case against Gefco and other asbestos companies. The next section explores some of the legal components necessary to justify litigation against industry under existing legal frameworks.

8.2.4 Grounds to Sue Under South African Law
The first question that must be answered before an individual decides to undertake legal action against a mining company is: does the individual possess the right to sue under the law? The individual's relationship to the mining company is extremely important when considering this question because different groups of people have different options for legal recourse. Once the individual's common law right to litigate is established, other legal issues arise, such as whether the mining company's alleged conduct can be considered wrongful under the law. An examination of several possible categories of potential claimants follows. It is important to note that this examination does not cover all the legal issues involved, but merely seeks to outline some of the difficulties each category might face in pursuing a legal claim.

8.2.4.1 Ex-Miners
One of the largest obstacles facing workers seeking legal recourse for ARDs is the compensation legislation itself. The Compensation for Occupational Injuries and Diseases Act of 1956 (COIDA), which covers most employees for injuries and occupational diseases sustained during the course of employment, eliminates an employee's common law right to sue his or her employer for these injuries, even in cases where the employer is negligent(115). The Act does permit an employee to recover increased compensation if the injury is caused by the employer's negligence; however, this additional compensation is prohibited if the employer can demonstrate that the employee's own negligence contributed to his or her injury in any way.

Most individuals who worked on asbestos mines or in asbestos mills are entitled to compensation for their occupational diseases under the ODMWA. Unlike the COIDA and other workmen's compensation legislation, the ODMWA does not explicitly prohibit an employee from taking legal action against his or her employer for the development of occupational disease. But, due to a provision in the Act that maintains that if a worker can be compensated under the ODMWA, he or she cannot collect compensation under "any other law." An argument can made that the Act takes away a worker's common law right to sue(116). In at least one instance, attorneys argued against this interpretation, but to date, no South African court has rendered a conclusory decision(117). As a result, any ex-mine worker covered by the ODMWA who brings a suit against his or her employer for negligence will have to establish that he or she retains a common law right to sue. While there are compelling arguments that can be made on behalf of potential claimants, this additional hurdle provides another disincentive on the part of workers and attorneys to attempt asbestos litigation in South Africa.

If a court determined that an ex-mineworker did possess the right to sue, he or she would probably have little difficulty establishing that the asbestos mining company's conduct was wrongful, because an employer generally has a legal duty to take "reasonable" steps to protect its employees from harm. However, even if the court finds this duty, the claimant would still have to show that the mining company's conduct was negligent, and that this negligence resulted in harm to the claimant. A good way for the claimant to prove negligence would be to present evidence that the company failed to meet South African safety standards.

Another relevant issue is whether South Africa's standards at the time of an individual's exposure were comparable to those of other countries. As it appears, South Africa had higher standards for acceptable fibre counts than the rest of the world(118). The result is that South African employees in the asbestos industry were potentially exposed to higher levels of dust. It is possible that a court could use the disparity between the safety regulations of other countries and those of South Africa to help determine whether the legally established safety precautions in South African mines and works were "reasonable" in and of themselves(119). However, whether a court would find such international comparisons persuasive remains to be seen.

8.2.4.2 Exposure to the Industrially Contaminated Environment
Individuals who develop ARDs due to industrial environmental exposure do not find themselves potentially stripped of the right to sue because of the provisions in compensation laws, but their ability to litigate successfully against the asbestos mining companies is hindered by other obstacles. Perhaps the most crippling of these is the claimant's burden of establishing that a particular mining company's asbestos caused or at least substantially contributed to his or her ARD. While this requirement does not prevent legal action, when combined with the insolvency of many of the asbestos mining companies, the frequent change of ownership of many of the asbestos mines, and the long latency period of ARDs, the case becomes increasingly complicated. Trying to determine the origins of any particular fibre is extremely difficult, and often impossible.

The claimant would also have to demonstrate that the defendant's conduct was wrongful; that the mining company owed the individual a legal duty that it subsequently breached. The existence of any regulations limiting the amount of dust an asbestos mine or mill could emit into the atmosphere might be sufficient for establishing this duty(120). In the absence of such regulations, the fact that the asbestos mining company was in control of hazardous property might in itself create a legal duty as to local inhabitants. However, claimants who have suffered from exposure to the contaminated environment may have a difficult time proving that the mining company acted negligently(121). Their success might depend on how effectively they can argue that the company knew or should have known that allowing asbestos fibres to escape into the atmosphere could cause harm to people living in the surrounding areas.

8.2.4.3 Women and Children Workers
Women and children workers pose different problems in regards to litigation. While legislation prohibited women from working underground, and children under the age of 16 from working at the mines altogether, women and children were employed at the asbestos mines in large numbers. The South African government facilitated the employment of both groups by granting exceptions for the employment of women and minor children with parental permission. Usually, women and children were employed to cob the asbestos by hand. This hand-cobbing was outlawed in 1973, but women continued in this and other occupations (at least in the Northern Province) up until the last mines closed(122).

The asbestos mine companies often failed to keep records of their employment of women and children. As a result, women and children claimants bear the burden of proving that they actually worked for a particular mining company. If they can prove their employment, and the employment was legal, then women and children litigants would likely face the same legal obstacles as male ex-mineworkers (see above). If they cannot prove employment, then they may face the same legal obstacles as environmental cases.

A different legal scenario arises when a woman or child can prove that they worked for a particular mining company but that the occupation itself was illegal. In such a case, the employee may find him or herself freed from having to circumvent the potential barrier to a common law cause of action under the ODMWA. However, in all likelihood, the court will find that illegal workers constitute de facto employees for the purposes of compensation legislation and workplace safety regulations.

8.2.2.4 Time Restraints on Bringing a Claim
A critical issue for all potential claimants in any litigation against the asbestos mining industry is whether or not their claim has been barred by the passage of time. Under the Prescription Act 68 of 1969, an injured party has three years from the time he or she could technically bring a civil suit against an alleged injurer to take legal action. However, the Act does provide that the limitation period will not begin to run until the injured party "has knowledge of the identity of the [alleged injurer] and of the facts from which the [injury] arises." This law also requires that the injured party make a reasonable effort to obtain this information(123).

South African courts do not require that the injured party actually know that they possess the right to sue; rather, they require only that the injured party be aware of the material facts that would support legal action, whether they have knowledge of the law or not(124). However, the courts do tend to use a more subjective approach (rather than a strictly objective one) in determining whether or not the claimant's attempts to acquire information are reasonable(125). This may be extremely important to claimants seeking to sue asbestos mining companies because it indicates a willingness on the part of the courts to take into account the particular case of each claimant. Under this approach, the court would likely consider apartheid conditions and the difficulty of obtaining relevant health and labour information in determining what constitutes "reasonable" behaviour.

8.3 Conclusion
Litigation is an important mechanism to hold accountable the multinational companies that abandoned their mining and milling operations without rehabilitating the mines, decontaminating the environment, or compensating those whose health had been compromised. As outlined in this section, there are many factors which make litigation difficult, especially in rural areas. However, asbestos was mined and milled in South Africa without protection for workers or the environment long after the health hazards were documented and accepted world-wide. Thus, the moral and legal right is on the side of those whose lives were so callously disregarded for almost a century.


  1. Act No 130 of 1993: Compensation for Occupational Injuries and Diseases Act. Government Gazette of the Republic of South Africa. Cape Town. § 35.
  2. The full text of § 100 of the ODMWA reads:
    "100. No person entitled to benefit from more than once source in respect of the same disease.
    (1)No person shall be entitled to benefit under this Act in respect of any disease for which he has received or is still receiving full benefits under the Workmen's Compensation Act 1941 [replaced by COIDA]
    (2) Notwithstanding anything in any other law contained, no person has a claim to benefit under this Act in respect of a compensatable disease as defined in the Act, on the ground that such person is or was employed at a controlled mine or a controlled works as defined, shall be entitled, in respect of such disease, to benefits under the Workmen's Compensation Act 1941 or any other law."
  3. In the matter of Zongerile v. Durban Roodepoort Deep Limited (Case No. 98/28484) the Plaintiff argued, in papers filed on May 31, 1999, that Section 100 of the ODMWA did not preclude an employee from suing his employer for negligence. No judgement was delivered in the case.
  4. It is also important to note that international dust and fibre levels were set in relation to a 40-hour work week. This is not the case in South Africa, as most asbestos mineworkers worked approximately 48 hours a week. As a result, even if the limits were the same, the South African worker would suffer more exposure as he or she would be subject to dusty conditions for a longer period of time. See National Union Mineworkers Submissions, Dust in the Mines. May 1994. Workplace Information Group: 2.
  5. A defendant in any asbestos action is likely to argue that the safety regulations promulgated by the government establish "reasonable" precautions per se.
  6. In order for a statute to create a legal duty as to a particular person, the person must be the type of person the legislation was intended to protect. Emissions regulations in general are enacted to protect the environment as well as persons; therefore, claimants who have suffered form exposure to the contaminated environment would most likely be considered to be members of the protected class.
  7. See Minister of Forestry v. Quathlamba (Pty) Ltd (1973) (3) SA 69 (AD).(Court held that defendant's control of hazardous property created legal duty).
  8. Davies, J.C.A., B.G. Williams, M.A. Debeil, and D.A. Davies 2001. "Asbestos-related lung disease among women in the Northern Province of South Africa."
  9. § 12 of the Prescription Act 68 of 1969.
  10. Loubser, M M. 1996. Extinctive Prescription. Juta & Co. Ltd: 104.
  11. Id. at 105-6. While any determination of what constitutes "reasonable" behaviour in the legal sense uses objective criteria, South African courts tend to narrow this objective approach to an individual's circumstances. The result is that the examination considers what "reasonable" behaviour would be for a similar person in similar circumstances. While this does not take into account an individual's specific intelligence, etc., it does look at what the general intelligence level, etc., of a person in the individual's position would be. The approach would perhaps be better described as "qualified subjective" rather than purely "objective."