Regulations

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Majority of the world still permits the use of chrysotile following safe use guidelines. For example, in the US, the regulations for amphibole asbestos and chrysotile are different. In Canada, there are strict workplace exposure limits for asbestos and emissions into the environment from mining are regulated. Russia permits concentrations of chrysotile of no more than 2 milligrams per cubic metre.

The case of Thailand

The import, usage and storage of asbestos is controlled by the Department of Industrial Work regulates and controls import, use, and storage of asbestos. In addition, the Labour Protection Law of the Ministry of Labour also provided regulations regarding asbestos. This provision indicates an occupational exposure standard level for asbestos in order to protect health of workers.

Crocidolite has been banned under the Hazardous Substance Act B.E. 2535 due to being a highly toxic chemical. 

Ministry Of Industry (MOI)

1. The Act on the Hazardous Materials B.E. 2535 (Buddhist Era), section 18

  • It is instructed that: For type 3 Hazardous Materials, any business for production, importing, exporting, or keeping in warehouse must have prior permission.

2. MOI’s enforcement on " List of Hazardous Materials B.E. 2538"

  • Asbestos, type chrysotile, is specified as “type 3 Hazardous Material"

3. Labelling regulations

  • Local Licensee is responsible for "International Sign" to be marked on product package/bag/pallet
  • The label shall be a white alphabet "a" on black background 
  • Warning clauses shall be in white or black alphabets on red background:
  • "Inhalation of the dust is dangerous to health"
  • "Be sure to follow the Safety Instruction"

4. The Office of Thai Industrial Standard (TIS)

  • TIS issued a specification of ordinary goods for 11 asbestos containing products, including asbestos-cement flat sheets, asbestos-cement high pressure pipes and fittings, etc.

Ministry Of Labour (MOL)

1. The Act on the Labour Protection, B.E. 2541, section 48

  • It is instructed that the employer is prohibited to allow the worker, who is under 18 years old, work in chemical materials area.

2. The Ministry Regulation, Volume 6 (B.E. 2541)

  • This was issued under the Act on the Labour Protection, B.E. 2541
  • It is instructed that the employer is prohibited to allow the worker, who is under 18 years old, work in the area of risk material for lung cancer, in production or transportation.

3. List of attachment under the Ministry Regulation, Volume 6 (B.E. 2541)

  • This was issued under the Act on the Labour Protection, B.E. 2541 (3) and has a provision on asbestos.

Ministry Of Public Health (MoPH)

1. The Act on the Public Health B.E. 2535

  • Section 31 instructs that the Minister is empowered to issue a list of hazardous business in the Government Gazette.
  • Section 32 instructs that the District Authority is empowered to issued a regulation on a business which is required permission.

2. Enforcement of the MoPH, Volume 5/ 2538

  • It is specified that the following lists are the Hazardous business:
  • Clause 7(7): Brake, Clutch.
  • Clause 11(8): Manufacturing of asbestos containing products, like brake, clutch, roofing tiles, floor tiles, fl at sheets, pipes, etc.
  • Clause 13(9): Building construction site.

Customs Department

1. Decree on Tariff and Duties , B.E. 2530, section 4

  • The exporting or importing of goods shall be charged duties as specified in the attached tariff lists.

2. Tariff and Duties

The tariff for brake/ clutch liners are imposed on 35% duties

The tariff for fire fighting clothes / packing rope are imposed on 30% duties

Ministry Of Interior (MoInt)

1. Enforcement of the MoInt

  • Subject: Safety instruction on working in chemical condition
  • Clause 5: The employer is prohibited to allow the worker, works in the area which has higher quantity of dust/fibre in the air, as shown in table 4, throughout normal working period.
  • Clause 6: The working area which is exposed to high dose of chemical materials, a controlled room or building should be provided for special isolation.
  • Clause 7: In the working area which is exposed to higher quantity of dust/fibre than Table 4, and the employer can not improve the said working condition, the employer have to provide the standard personal safety device for all workers.

2. Table 4

  • The Threshold Limit Value (TLV) = 5 fibres/cc
  • Standard TLV of airborne fibre in working condition

Ministry Of Natural Resources & Environment (MoN&E)

  • Safety Instruction on working with Chemical Materials, including asbestos
  • Information on hazard, house-keeping, and disposal, etc.

Regulations in North America and Europe
Until recently, leading regulatory agencies did not distinguish the differences between amphibole and chrysotile types of asbestos in their policy. But with the evidence of up to date scientific and epidemiological studies these agencies have begun to revise approaches to asbestos policy.

Two leading countries, the United States and the United Kingdom have been revising their positions and regulations concerning the industrial use of chrysotile.

United States

http://www.epa.gov/oswer/riskassessment/asbestos/

In 2001, Environmental Protection Agency (EPA) has started to revise their outdated U.S. EPA model for lung cancer and mesothelioma based primarily on a document completed in 1986 (U.S. EPA 1986). The main feature of the last U.S. EPA model for lung cancer and mesothelioma is that this model did not take into account differences in type of asbestos fiber. In other words, according to this model, all fiber types have equal potency of causing cancer.

In 2003, scientists D. Wayne Berman, Aeolus, Inc. and Kenny S. Crump, Environ Corporation prepared a document by request of U.S. EPA. The final draft of this document is called “Final Draft: Technical Support Document For A Protocol To Assess Asbestos-Related Risk”.

This document stated that:
"The approach currently employed at the U.S. EPA to evaluate asbestos-related risks (IRIS 1988) is based primarily on a document completed in 1986 (U.S. EPA 1986) and has not been changed substantially in the past 15 years, despite substantial improvements in asbestos measurement techniques and in the understanding of the manner in which asbestos exposure contributes to disease. Therefore, this document provides an overview and evaluation of the more recent studies and presents proposed modifications to the protocol for assessing asbestos-related risks that can be justified based on the more recent work."

AND:
"Results in Table 7-17 also differentiate between the potency of chrysotile and amphibole for both lung cancer and mesothelioma. Amphibole is estimated as being about four times as potent as chrysotile for lung cancer (although the difference is not significant) and about 800 times as potent as chrysotile for mesothelioma (a highly significant difference). Moreover, the data are consistent with the hypothesis that chrysotile has zero potency toward the induction of mesothelioma."

Based on this document, EPA is going to change its outdated model for lung cancer and mesothelioma in recognition of the huge difference between chrysotile and amphiboles. The agency will have two different formulas describing exposure to chrysotile and to amphibole asbestos instead of one.

United Kingdom

http://www.hse.gov.uk/aboutus/meetings/hscarchive/2006/040706/c55.pdf

In June 2006, Kevin Walkin and Geoff Lloyd under the lead of Giles Denham, a board member, prepared a risk assessment paper for the Health and Safety Executive (HSE) of the United Kingdom. This document is called "A Comparison of the Risks from Different Materials Containing Asbestos."

HSE agreed that there should be a risk-based approach to the licensing of asbestos, with licensing reserved for high risk products and processes.

The document stated that: "The epidemiological evidence from asbestos workers and well-conducted animal tests shows that while all types of asbestos share the same hazards (e.g. the potential of an early death from lung cancer, asbestosis and mesothelioma) they have varying degrees of risk (the likelihood that death from one of the hazards will occur). The relative risk from the same level of exposure but to different asbestos fibre types is shown in figure 1 (see graphics on page 6,7,8,9 and 10 of present document) as derived by Hodgson and Darnton, 2000. The relative risk from crocidolite asbestos is some 500 times greater than chrysotile asbestos and the relative risk from amosite asbestos is 100 times greater than chrysotile asbestos. This means that the type/s of asbestos in the product are particularly significant when assessing risk." 

"The results for the lifetime risk in figure 6 for 40 years exposure from the age of 20 represent a worst case continuous exposure situation. The highest risk is by far the one caused by sprays and other insulation groups (risk 11,419 per 100,000) and AIB (risk 1,642 per 100,000). These are the two licensed groups. The next highest group is the jointings and packings, (risk 55 per 100,000) but as the risk is mainly associated with the amount of crocidolite and amosite asbestos products remaining and many gaskets and packings are replaced during routine maintenance and servicing, this is likely to be an overestimate of the remaining risk. Some of the products in this group if present for thermal insulation would be regarded as licensed materials."

"All the other groups are essentially non-licensed products (textured coating –i.e. some fillers and reinforcements are currently licensed). It can be seen that the nonlicensed product groups have an over a thousand times lower risk than licensed sprays and other insulations group and over a hundred times lower than the licensed AIB and millboard groups."

The same exposure situation was used to calculate the annual risk of death based on an average survival age of 80. See figure below: 

Figure 1: Annual risk of death per million based on 10% of time actively removing ACMs from age 20 to 40 years with limited controls: no RPE 

"The more detailed assessment by product group showed again that by far the highest risk resides in the two product groups that contain licensed asbestos materials. The next highest risk group is jointings and packings, which contain some materials that would in some situations be regarded as licensed. The calculated annual risk of death for 40 years of exposure from age 20 are compared to the risk from other workplace fatalities in figure 9 (and HSE statistics 2004) and the lower rates for non-licensed materials are compared to public / societal risks in figure 10 (see R2P2 (2001) and Royal Society, 1981). Again, it is important to remember that the estimated asbestos risk for a population of frequently exposed workers has been based on the use of limited controls and no use of RPE with 40-year duration of exposure and must be regarded as an upper estimate."

Figure 2: Comparisons of textured coating an asbest cement product group annual risk of death per million to other public risks. (Asbestos risk based on 10% of time actively removing ACMs from age 20 to 40 years with limited controls and no RPE)

Canada

http://hc-sc.gc.ca/iyh-vsv/environ/asbestos-amiante_e.html

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