9.1 - Introduction: The Amended Asbestos Regulations
9.1.1 - Medical Surveillance Requirements in the Amended Asbestos Regulations
9.1.2 - Integration of Occupational Health Regulatory Body
9.1.3 - Industry Reaction
9.1.4 - Internalisation of the Social Cost of Asbestos
9.2 - Findings
9.2.1 The Need for a Ban on Chrysotile Asbestos
9.2.1.1 - Inadequate Enforcement
9.2.1.2 - Non-Compliance with Health and Safety Policies
9.2.1.3 - Inherent Risks of Chrysotile Use
9.2.2 - Safety of Chrysotile Substitutes
9.2.3 - Substitution in South African Asbestos-Manufacturing Industries
9.2.3.1 - Technical Barriers to Substitution
9.2.3.2 - Economic Barriers to Substitution
9.2.4 - Substitution and Job Loss
9.2.4.1 - Conditions for Substitution
9.2.4.2 - Substitution Does Not Necessarily Result in Job Losses
9.0 - COMMISSION 4: THE ASBESTOS INDUSTRY AND ITS FUTURE APPLICATIONS
"There is no future for asbestos in South Africa." - Industry Representative
9.1 Introduction:
The Amended Asbestos Regulations
The Fourth Commission of the 1998 National Asbestos Summit formally brought
together stakeholders in the asbestos-user industry, including company representatives,
trade unions and NGOs. This group acknowledged the problems of job losses in
these industries, as well as the continued exposure of workers to possibly harmful
conditions at all stages of chrysotile use. They produced a list of consensus-based
recommendations for improved workplace safety, and called for a ban on chrysotile
asbestos, and increased use of substitute materials. While some of the recommendations,
such as an asbestos substitution working group, have not yet been implemented,
many of the concerns about workplace safety have been incorporated into the
Amended Asbestos Regulations, which were drafted by the DoL Advisory Council.
The same groups that participated in the 1998 Summit were represented on a tripartite
Advisory Council that was responsible for the basic structure of the regulations.
The new regulations broaden the scope of regulated workplaces and activities.
In August 1999, the DoL published a notice of the Draft Amended Asbestos Regulations and asked for public comment. The new regulations increase the number of workplaces required to follow asbestos-related health and safety procedures by incorporating contractors, building supervisors, and people working in most other places where asbestos products are present. The regulations also shift the burden of proof regarding the presence of asbestos materials in a building or work-site from workers and tenants to employers and building supervisors. There are also more stringent requirements for medical surveillance, workplace air monitoring and licensing of asbestos material maintenance workers(126).
A trade union representative stated that while the emphasis in new regulations on preventative measures was a major improvement over the past rules, he remained very disappointed by the omission of procedures for a phase-out of chrysotile. Such a phase-out had also been negotiated at the 1998 summit, and the lack of resolution reveals the continued disagreement between manufacturers and labour on this question. The phase-out debate focuses on chrysotile asbestos, because it is the only form of asbestos currently used by South African manufacturers. Even though no codified ban on amphibole asbestos exists, manufacturers now tend to avoid the material.
9.1.1 Medical
Surveillance Requirements in the Amended Asbestos Regulations
One of the most important changes is the requirement for medical surveillance
for workers exposed to fibre levels above the approved action level of 0,1 f/ml.
A submission to the DoL by groups from different centres in the country strongly
recommended that asbestos risk assessment as well as adequate medical surveillance
and a model asbestos medical surveillance programme for inclusion in the amended
asbestos regulations(127). This change
is especially welcomed by trade unions in the construction sector; such a programme
had been sought by the construction workers union CAWU for many years(128).
All of the manufacturers with whom we spoke mentioned ongoing surveillance programmes
that they claimed satisfied the new requirement. In the case of Everite, the
only company whose health surveillance programme we looked at in detail, the
current plan is a product of negotiations between trade union representatives
and management over a period of many years. One occupational health specialist
who had worked with Everite to revise its surveillance programme in 1997 cited
several major changes including: increased frequency of inspection, ARD diagnosis
training for health professionals, the use of International Labour Organisation
(ILO) X-ray standards, and an independent audit programme for surveillance records.
This specialist also suggested that the optimal implementation of the surveillance
programme seemed to occur during successful financial periods, but that recent
market and political pressures had caused the quality of the programme to deteriorate.
The occupational health specialist also highlighted the distinction between surveillance for current and former employees. The new regulations do not require post-employment surveillance, which is critical for identifying and tracking cases of the diseases, given the long latency period of ARDs. The omission of such a requirement from the Amended Asbestos Regulations is therefore seen as a major flaw. Post-employment surveillance is required for mineworkers under ODMWA, but any existing programmes among asbestos-using manufacturers are the result of trade union negotiations with management.
Everite offers free annual medical examinations for former employees in cities where the company currently or previously operated a factory. The company also provides former workers with durable cards that detail their asbestos exposures, and are designed to be presented to health care providers unfamiliar with ARDs. The Everite representative reported that at the onset of their post-employment surveillance program, they made an effort to locate and enrol former workers. Everite was the only company we spoke with that discussed a post-employment surveillance program. Of the others, one was explicit about not accepting any responsibility for post-employment surveillance.
Both the trade union representative and the occupational health specialist with whom we spoke expressed concern about Everite's post-employment surveillance program. According to them, there is a high turnover rate in the private doctors hired by Everite to provide the examinations, not all of the practitioners have training in ARD diagnosis, and health records of former employees are disappearing. Some workers have reported dismissive attitudes among these practitioners and feel that they are more conservative in their diagnoses and submission of claims forms. The trade union representative also reported that some former workers were confused by the frequent changes in doctors, and some are sufficiently frustrated to no longer seek examinations.
9.1.2 Integration
of Occupational Health Regulatory Body
Beyond the new protective measures and surveillance requirements, one of the
most important functions of the new regulations is to integrate the fragmented
occupational health laws on asbestos. One official in the Occupational Health
and Hygiene section of the DoL indicated that fragmentation was one of the most
serious problems with health and safety regulation. Just as in compensation
and health provision, this fragmentation results in both wasteful redundancies
and gaps in enforcement. The new regulations are intended to enable more coherent
enforcement and inspection systems and to reduce confusion for employers.
9.1.3 Industry
Reaction
According to DoL officials, the items that drew the most comment from industry
were the requirements for medical surveillance programmes and the tightened
action level for asbestos, which dropped by an order of magnitude to 0,1 f/ml.
Industry opposed both as too expensive. The Labour official we interviewed suggested
that this was precisely the intent -- that introducing a prohibitively low action
level would be tantamount to a ban on asbestos, and would also serve to improve
occupational health during the transitional period.
Most of the manufacturing companies we interviewed indicated they were already engaged in the proposed new practices and expressed little concern about official implementation of the new regulations. As discussed above, these companies indicated the presence of ongoing medical surveillance programmes, although these did not always include pre-employment examinations or post-employment monitoring. Company representatives claimed that fibre counts were now well below the current standard of 1 f/ml, though many were above the level of 0,1 f/ml. Though one representative said that the expense of converting equipment to conform to the new regulations would force them to close the plant, this was not typical of the company representatives that we interviewed.
Some also questioned the inclusion of construction contractors and of those who maintain and demolish asbestos-containing structures in the amended regulations as an inappropriate extension of the DoL's authority. According to DoL officials, registration and licensing of maintenance work crews are essential to preventing exposure for these workers. Furthermore, licensing requirements professionalise asbestos maintenance work, thereby empowering workers who have training and experience with the specific protective procedures. The requirements for increased workplace inspection and monitoring create a market for the provision of these services, thereby providing skilled labour opportunities. These new opportunities may offset the recent job losses in manufacturing sectors, and those that may occur during the conversion to substitutes.
9.1.4 Internalisation
of the Social Cost of Asbestos
The new monitoring requirements and reduced workplace exposures called for in
the Amended Asbestos Regulations are important in internalising the social costs
of asbestos use. Because health risks have been borne by labourers and building
occupants rather than those who make purchasing and production decisions, the
cost of asbestos use has been artificially low. Including the expense of mitigating
these health risks makes evident the full cost of asbestos use and may encourage
consumption of non-asbestos products. In section 10.2 of the new regulations
there is a direct call for the use of substitutes when possible, but the cumulative
expense of the other requirements may be more influential in persuading companies
to make this transition.
When questioned about the future of the asbestos industry in South Africa, one company representative scoffed, "there is no future for asbestos in South Africa." Because of changes in market demand, substitution is the only option for South African asbestos-using manufacturers. This is why we chose asbestos substitution, from among all the important topics in the 1998 Asbestos Summit and Amended Asbestos Regulations, as the focus for this section of the report.
9.2.1 The Need for a Ban on Chrysotile Asbestos
9.2.1.1
Inadequate Enforcement
Representatives for asbestos-user manufacturers did not indicate cost as a widespread
concern regarding the upcoming Amended Asbestos Regulations. However, the representatives
did deem existing health and safety measures prohibitively expensive, and cited
that expense as a major impetus for substitution development. While this regulatory
burden is one reason for conversion to chrysotile substitutes, many companies
simultaneously described a reduced frequency and intensity of inspection of
the workplace by DoL officials.
Representatives of the DoL also voiced concern about inadequate enforcement. Industry indicated that they rarely see government inspectors, and maintained that they voluntarily follow regulations because they have an interest in healthy workers. While such voluntary compliance may seem to be an ideal mechanism for workplace safety, we have seen that in the case of many industries, including mining and manufacturing of asbestos in South Africa, that self-regulation is not sufficient to protect workers. The DoL representative revealed that the Occupational Health and Safety division needs additional resources to train inspectors and properly enforce the upcoming regulations. One health and safety representative echoed this observation, saying that the DoL did not have "enough soldiers on the floor." DoL officials noted that resources for training inspectors were limited, and that the department had recently undergone an "experience drain" leaving only a few practised inspectors to train a large number of new recruits.
9.2.1.2
Non-Compliance with Health and Safety Policies
Another requirement in the Amended Asbestos Regulations is for those who manufacture
asbestos-containing products to inform their customers of health risks and proper
procedures. The compliance of these downstream users is extremely important
in an evaluation of the safety of chrysotile asbestos. Everite explained that
its larger customers with full-time employees are generally diligent about adhering
to safety procedures, but expressed concern about the customers referred to
as "bakkie builders," who purchase smaller volumes and are likely
to be unlicensed contractors hiring temporary labour. The "bakkie builders"
are known for using angle grinders and other construction methods that release
asbestos fibres from high-density cement products. One trade union representative
discussed the many risks faced by workers using asbestos-containing materials
at construction sites. Despite information on proper procedures provided by
the asbestos-cement manufacturers, dangerous practices like high-speed dry cutting
and sanding occur. Inevitable sheet breakage, and abrasion between sheets during
the manual unloading of trucks still results in exposure to asbestos fibres.
A related concern is the difficulty in ensuring that employees adhere to company policies on personal safety. Representatives from almost every company we interviewed voiced this concern, faulting both supervisors and workers for failing to enforce the health and safety standards. A common allegation was the failure to use masks properly, especially during the hot summer months and among employees with eyeglasses or facial hair. One health and safety representative recalled that many employees place masks on their foreheads rather than in sealed bags after leaving a protected area. However, the trade union representative expressed concerns about the adequacy of the masks, even when used correctly. Many do not form a proper fit around the nose or facial hair, the straps often break, and cheaper masks are prone to cause irritation. The union has pushed for more effective moulded plastic masks for workers in the highest exposure areas. The trade union representative explained that official company education programmes about asbestos' dangers are inadequate, and many workers do not fully understand the necessity of personal protection equipment (PPE). According to the representative, workers who do wear the equipment are influenced largely by union education programmes and direct knowledge of co-workers' illnesses.
The ultimate cause of workers neglecting masks is unclear, but these incidents are particularly troubling because such masks are often the last provision of protection when an accident occurs or general procedures fail to reduce fibre concentrations to the level where action is mandatory. This is why the trade union favours the prioritisation of engineering solutions like extraction fans instead of reliance on PPE. One major safety improvement is the installation of automated asbestos bag openers that dramatically reduce fibre levels in the raw material area of the plant. We observed these automated loaders in several of the facilities that we were able to visit, but the AC Pipes plant at Kliprivier still uses manual loading. There is conflict between industry and trade unions on this issue because engineering solutions are usually more expensive than PPE. The union representative said that they will continue to push for safer engineering practices even with the ultimate goal of a chrysotile ban.
9.2.1.3
Inherent Risks of Chrysotile Use
It is evident that health risks persist under the current system. According
to the asbestos industry, the safety of chrysotile is predicated on its "safe
and controlled use." If this safe use cannot be ensured, despite the efforts
of manufacturers and inspectors, then chrysotile is inherently too dangerous
for continued use in South Africa. Worker and customer non-compliance with safety
regulations is not peripheral to the discussion of the safety of chrysotile.
If the human components undermine the protection programmes of these industries,
then production must be changed to incorporate less intrinsically hazardous
substances. Furthermore, the continued risks to foreign miners extracting asbestos
for South African markets must be considered in a cradle-to-grave consideration
of occupational health and safety. According to anecdotal evidence, Zimbabwean
mineworkers are routinely exposed to unsafe levels of asbestos fibres and there
is little attempt to improve conditions(129).
To provide demand for Zimbabwean asbestos is to be complicit in the health risks
faced by these workers.
Chrysotile consumption by South African manufacturers has declined dramatically in recent years due to substitution programmes and plant closings that are discussed later in this section. But because of the inherent risk of chrysotile use it is irresponsible to rely on market mechanisms alone to eliminate chrysotile use. There must be a proactive policy to end the use of chrysotile.
9.2.2 Safety
of Chrysotile Substitutes
To recommend that chrysotile be phased out, we must be sure that the alternatives
are safer. Trade union representative expressed concern about the materials
used in the new formulations and said that the union was pressuring management
to ensure that no new occupational hazards are introduced. As one industry representative
stated bluntly, "it would have been madness to go from asbestos to anything
that was particularly problematic." Fortunately there has been a substantial
amount of international research regarding the toxicity of substitutes compared
to chrysotile. Substitute fibres that have mechanical and chemical affinity
to chrysotile are also prone to share its toxicity. As one company representative
noted, asbestos is one of the best-studied industrial materials in the world,
and it is being replaced with materials we know far less about. In the industry
view, conversion to substitutes now involves "abandoning the frying pan
for the fire." However, a leading researcher at a United States university
who specialises in the carcinogenicity of synthetic fibres told us in an interview
that these studies are essentially complete. This conflict illustrates an uncertainty
in toxicology research- chrysotile asbestos can be "proven" dangerous,
but its substitutes can never be "proven" safe. An insistence on waiting
for absolute scientific evidence of the safety of substitutes denies the reality
that we frequently make health-related regulatory decisions without conclusive
information(130).
The subject of the relative toxicity of chrysotile and its substitutes is discussed extensively in a United Kingdom Health and Safety Executive document entitled Chrysotile and its Substitutes: A Critical Evaluation(131). The Institute for Environment and Health, which produced the document, undertook an extensive literature review on the topic and concluded that several major substitutes: polyvinyl alcohol, cellulose and aramid fibres, and wollastonite, are less hazardous than is chrysotile. This assessment is based on the three essential fibre properties that determine toxicity: length-to-diameter ratio, persistence of the fibre in the body, and the propensity of a material to release fibres. However, there are a number of substitute materials used by industry in South Africa that are not directly discussed in the report. Particularly important among these are silica, fibreglass and refractory ceramic fibres. The latter two are classified as possible human carcinogens by two related indices, those of the International Agency for Research on Cancer (IARC) and the United State's National Toxicology Program Report on Carcinogens. Fibreglass has been recognised as an irritant to the upper respiratory tract as well as the skin and eyes(132). One South African company uses refractory ceramic fibres in its asbestos-free products, while another dismissed them as a component of its formulation because of their possible carcinogenicity. Silica is also a controlled substance under South African law and is known to cause silicosis and is also considered to be carcinogenic.
Given the risks presented by these substitute materials and their increasing use, it is important that occupational health and safety regulations on emergent substitute fibres remain current with those of other industrialised countries. The state occupational health body must be fastidious in monitoring the health effects of substitutes to avoid exposing workers to risk. It would be dangerous to eliminate asbestos-related health surveillance programmes already in place, as these will provide the earliest warning if any of these substitutes present problems.
9.2.3 Substitution
in South African Asbestos-Manufacturing Industries
Once the indisputable need for chrysotile elimination and substitution is accepted,
the stakeholders in the asbestos-user industries will confront issues of job
loss. Substitution is one of the important issues raised in the Fourth Commission
of the Summit Report because it directly affects the livelihood and safety of
a great number of workers, and because the research and development involved
reflects the greater ethical accountability of socially responsible industry.
The transition to asbestos substitutes has been underway in industrialised countries since the late 1970's, but is occurring more slowly in South Africa. To evaluate this delay, it is vital to understand both the general and specific problems in converting production to substitute materials. We interviewed five Gauteng asbestos-user manufacturers producing a wide range of products to assess the status of substitution(133) and found a corresponding diversity of results and prognoses for further reductions in chrysotile use.
9.2.3.1
Technical Barriers to Substitution
The two major obstacles reported by industry representatives are the expense
of non-asbestos substitutes and the technical challenges of their development.
Most of the companies we interviewed cited technical difficulties as a significant
source of delay with substitution programmes. In the late 1980's Everite attempted
to adopt an asbestos-free cement technology known as "Nutec." However,
technical barriers impeded the use of "Nutec" in moulded goods and
profile sheets used for roofing. The company had publicly announced that its
Kliprivier, Gauteng plant would be asbestos free by August 2001, but because
of problems with equipment installation the target date for 100% conversion
has been postponed to February 2002.
Other companies have reported greater barriers. Insulectric, which produces insulation boards for industrial and railway applications, has not yet developed a commercially viable asbestos-free board to meet demand. This technology has been elusive because insulation boards must withstand extreme conditions to meet safety standards. The company is currently testing a locally developed substitute. AC Pipes reported the most difficulty with substitution because of high performance requirements. It has been unable to develop an asbestos-free high-pressure pipe, an application that accounts for 80% of their market. The investment in current investment equipment makes it difficult or expensive to switch to alternatives(134). Furthermore, PVC alternatives are only useful for small diameter pipes (<300mm) and steel for larger ones (>450mm) so asbestos cement has no alternative in the middle size range(135).
9.2.3.2
Economic Barriers to Substitution
According to industry officials, another impediment to substitution is the relatively
high cost of other materials, and the expense of converting production capital
to utilise these substitutes. Conversion of Everite's manufacturing technology
to "Nutec" was expensive, costing approximately R80 million. The result
was that the company could not afford to convert both Brackenfell and Kliprivier,
its two major plants. Everite opted to consolidate their operations at the latter,
eliminating approximately 400 jobs at Brackenfell. Interviews with bread winners
whose jobs were "eliminated" speak of great family hardship at the
loss of gainful employment at such short notice. They considered the Brackenfell
plant to be profitable and blame bad management decisions and lack of transparency
for the summary closure of the plant. The Brackenfell closure is only the latest
in a long series of closures by Everite around the country, mainly in the past
three years.
In the production of industrial gaskets and packing, Klinger has succeeded in converting about half of its production to substitutes, but continued market demand for asbestos-containing materials precludes any further conversion. Customers are reluctant to pay the increased cost for substitutes- raw material prices are often four to five times that of asbestos. Most of the expensive substitute fibres are imported, and representatives from Klinger expressed concern that by purchasing raw materials outside of the country the company was putting strain on the nation's foreign exchange. In contrast, Zimbabwean chrysotile is paid for in rand, thereby strengthening the local currency. Interestingly, asbestos-user industries imported chrysotile asbestos even when it was mined in South Africa.
Several companies expressed concern that the production volume associated with lower demand for non-asbestos products would not sufficiently utilise production capacity, making continued operation unprofitable. Overcapitalisation is particularly problematic during the transition because manufacturers are more sensitive to increased raw material prices. The AC Pipes representatives indicated that if volume is significantly depressed, revenues will be insufficient to cover overhead costs, and if this situation is extended, the Kliprivier factory will have to close.
Ironically, substitutes may become increasingly cost competitive as the price of asbestos increases. According to one company representative, decreasing sales of raw fibres has forced Zimbabwean mines to increase their costs per unit in order to cover fixed costs. While this trend will make asbestos substitution relatively less costly, the absolute costs of production are still increasing.
9.2.4 Substitution
and Job Loss
Preventing job loss is an important consideration in the transition to substitutes.
As previously mentioned, Everite reports that their conversion to "Nutec"
was too expensive and too sudden to allow the conversion of both major facilities,
resulting in the closing of one, Brackenfell, and the retrenchment of approximately
400 workers. At Insulectric, the manufacturing workforce has been reduced from
20 to 6 because of the inability of the company to respond quickly to market
changes. Insulectric representatives said that if a ban on chrysotile manufacturing
comes before the company realises commercial production of its new insulation
board, they would likely cease operation. Klinger expressed a similar concern.
They assert that a ban on domestic chrysotile manufacturing would cause half
of their market to begin importing asbestos-containing materials, necessitating
the elimination of half of Klinger's 225 workers.
It is important to point out that the framing of the substitution issue by industry as jobs versus safety has prolonged the development of conversion to substitutes since the hazards of asbestos became clear. Markets for asbestos-containing products began to decline in the late 1970s, a trend that could not have gone unnoticed by the European owners and licensors of South African manufacturers. The labour representatives we spoke with expressed their belief that despite the technical difficulties companies face, twenty years of preparation should have been sufficient to prevent the closures of major facilities and the current crisis of abrupt transition.
9.2.4.1
Conditions for Substitution
The case of Hudaco Friction, a company that began conversion to substitutes
in 1978, demonstrates that substitution can be viable from an economic perspective,
if not a health one(136). Not only
did Hudaco have access to research capital, but the company's response to market
changes was timely, enabling them to remain ahead of domestic market trends
and prevent major retrenchments. The contrast between Hudaco and the other manufacturers
is illustrative of transition behaviour that does not force a choice between
jobs where workers are exposed to asbestos, and no jobs at all.
Hudaco produces automobile disk brakes and brake linings, and is nearly 100% converted. Because Hudaco supplies auto parts to European automakers, the company is licensed under European standards, which began in 1978 to phase out all types of asbestos in passenger car disk brakes. Hudaco's licensors supplied the company with formulations for asbestos-free disk brakes, for which they pay royalties each time the brakes are sold to European or South African contractors. This arrangement enabled Hudaco, which otherwise would not have had the capital for research and development, to continue operating. Being bound to European standards also meant that Hudaco became aware of the Western asbestos-substitution thrust with ample time remaining to perfect formulations before the movement arrived in South Africa.
Hudaco's other product line, friction brake linings, has been partially asbestos-free for several years, and with the recent development of asbestos-free linings for the lower cost end of the product series, will soon achieve complete conversion. Because Hudaco was able to invest in friction-lining research without pressure to abruptly convert, they were able to ensure the performance characteristics before releasing them to market. The Hudaco representative offered the story of Ferodo, another South African brake manufacturer that experienced the opposite. Because Ferodo's licensor demanded immediate conversion, the company did not have time to perfect their formulations, and they temporarily lost much of their market.
9.2.4.2
Substitution Does Not Necessarily Result in Job Losses
Ideally all manufacturers would have sufficient capital for research and development
of asbestos substitutes. Unfortunately this is not always the case, particularly
with smaller producers. Alongside capital, time is an essential element of the
conversion. Industry representatives repeatedly stressed the need for research
and development time. Other stakeholders, in particular workers at risk of exposure
to asbestos, feel that industry has intentionally delayed substitution, squandered
the transition time they were given, and created their own "crisis."
One company has been researching substitutes for two decades and instead of
protecting jobs at the end of this period retrenched workers at very short notice.
As in many regulatory situations, the imbalance of information favouring industry
makes it difficult to confirm or deny the companies' claims that research targets
are unattainable.
From our interviews we identified a number of possible factors that might reduce the job losses associated with substitution.
The prospect of a chrysotile ban is complicated by the possibility that some applications may not have technically adequate substitutes. Some members of the European Union banned the use of all forms of asbestos in 1997, but have since issued exemptions for certain specific application because manufacturers could not find substitutes that performed as well as asbestos(137).
While these are the conditions trade unions would like to see, it is unclear how such a model would be accepted by industry. The union representative stated that the Congress of South African Trade Unions (COSATU) office in Parliament would continue to pressure for a ban on all forms of asbestos, and it is likely that many aspects of the transition plan just described would be a part of the suggested policy.
9.3 Conclusion
The social costs of asbestos have been borne by the workers who mined and milled
asbestos and manufactured asbestos-containing products in South Africa since
the late 19th century. Asbestos use is now in decline, yet workers continue
to bear a great burden through the loss of their jobs and due to health effects
of past and current exposure to asbestos. Many workers argue that the severe
retrenchment in industry could have been prevented with better management practices
and more timely conversion to substitutes.
Stakeholders approached the prospect of an asbestos ban quite differently. It is evident from the Amended Asbestos Regulations that the DoL favours a financial disincentive for asbestos use. Industry repeatedly expressed that their ongoing conversions to substitutes were motivated by the market rather than by any belief that industrial chrysotile use is dangerous. In the Fourth Commission of the National Summit Report, consensus-based resolutions were passed to phase out chrysotile asbestos and convert to substitutes. Despite this consensus, we found considerable resistance to both resolutions among industry representatives based on their assertion that chrysotile can be used safely in the modern industrial setting. Industry's argument for a gradual transition -- essentially changing their production at the pace insisted upon by the market rather than that demanded by health concerns - is based on this belief. Manufacturers' continued insistence that chrysotile is safe necessitates a reframing of the risk discussion to include cradle-to-grave dangers and a recognition of compliance difficulties. These issues demonstrate the unequivocal need for a ban on chrysotile use and for a rapid transition to safer substitutes. Below we provide some suggestions to alleviate subsequent issues with job retention and protection of employee safety.
- Ban the manufacture and importation of chrysotile-containing products.
- Further integration of the occupational health and safety regulatory body is still needed to increase the efficiency of interdepartmental collaboration and expertise transfer. Additional resources may be necessary for optimal DoL inspector training. The Advisory Council that drafted the Amended Asbestos Regulations should consider alterations put forward by members of the IHRG to improve the efficacy of current surveillance and post-employment surveillance programmes.
- Maintain health and improve surveillance and industrial hygiene measures already in place, because of the occupational risks with many asbestos substitutes. International research on the toxicity of such materials and domestic health surveillance reports should be closely monitored.
- Consider innovative ways of job protection by using the experience of asbestos-user companies to move into asbestos risk assessment, adequate control of asbestos-in-place and effective disposal of waste products.
- Given the long latency of ARDs, it is essential that there be post-employment surveillance for all workers leaving asbestos-user industries.
- Implement post-employment surveillance for all workers leaving asbestos-user industries, given the long latency of ARDs.
- Encourage continued openness between industry and labour. Also, facilitate democratic involvement in issues of concern to workers.