The position of International Trade Union Movement For Chrysotile of non-inclusion chrysotile Into Annex 3 of Rotterdam Convention
In accordance with Rotterdam Convention procedure, the question of the inclusion of chrysotile asbestos in Annex III has been considered on two occasions by the Chemical Review Committee, and also at the third, fourth, fifth meetings. No decision had been taken due to lack of consensus. Chrysotile asbestos is again on the agenda of the sixth meeting of the Conference of the Parties to the Rotterdam Convention
This crusade against chrysotile asbestos must end.
The inclusion of chrysotile to the PIC list of the Rotterdam Convention must raise international concerns and would go beyond the principles of the Convention.
The crusade by a well organized group of activists is calling for a global ban, arguing on the heritage of the past misuse and high exposures of different asbestos fiber types, in particular the amphiboles. This crusade is generally based on the misrepresentation and selective quotations of published evidence, never taking stock of the recent studies showing the vast differences in health risk between chrysotile and the amphiboles. It is striking that the most aggressive interventions have been generally limited to «asbestos», in careful ignorance of any mention of the proven fiber differences between «asbestos» fiber types. Having in mind that the word «asbestos» is a generic word and a commercial term to indicate any silicate, fibrous mineral with a fibrous form. Today, only chrysotile is commercially exploited in any appreciable manner and about 90% of the fiber production is used in the manufacture of cement products where the fiber is firmly encapsulated in the matrix and therefore not airborne.
As the international the ILO recognized in 1986, and many countries afterwards, regulations on asbestos use must be based on scientific reality, not on perceptions or business interests. Some five hundred other products and industrial processes are recognized as carcinogens, but this does not mean that we must prohibit their use. In addition to the ILO, many international organizations favour a controlled over a ban (silica is a good example).
Because all types of asbestos were used incorrectly in the past, we know that chrysotile and amphiboles have been classified as category 1 carcinogens (proven carcinogenic agents), such as
cadmium, chromium, nickel compounds, silica, the sun’s rays, vinyl chloride, alcoholic beverages, salted fish, tobacco smoke, saw dust, the manufacture of furniture and cabinets, iron and steel foundries and the rubber industry. The International Agency for Research of Cancer (IARC) classification identifies a substance’s hazard, not the risk. Consequently, a substance classified in group 1 does not mean that we should prohibit its use, only that it should be properly controlled.
The World Health Assembly (WHA — 2007) resolution adopting a Global Plan opens risk management scenery within chrysotile regulations. It states in its Annex (to devise and implement policy instruments on workers health) the following:
«WHO will work with Member States to strengthen the capacities of the ministries of health to provide leadership for activities related to workers health, to formulate and implement policies and action plants, and stipulate intersectoral collaboration. Its activities will include global campaigns for elimination of asbestos – related diseases – bearing in mind a differentiated approach to regulating its various forms — in line with relevant international legal instruments and the latest evidence for effective interventions, as well as immunization of health – care workers against hepatitis B, and other actions addressing priority work – related health outcomes».
First of all, the fact that “chrysotile” asbestos and fibers in the “amphiboles” group are regulated differently is nothing new. This differentiating approach exists in the ILO Convention 162 on the safe use of asbestos issued by the ILO. Since “asbestos” is a trade name rather than a technical term, it is appropriate that the regulation take into account the main differences between the types of fibers.
Furthermore there are many studies and an international consensus, that show that chrysotile fiber (white asbestos) is definitely less dangerous. This certainty is the foundation of the ILO convention, as well as the regulations of most countries in the world. Two significant scientific
Events recently confirmed this fact: (1) a group of scientists mandated by EPA unanimously agreed that available studies on epidemiology indicate that the carcinogenic potential of amphibole fibers was one hundred times higher than that for chrysotile fibers. (2) An important study on the biological persistence of chrysotile in the lung has shown, taking into account the scientific literature to date, that the report on this study provides solid new data that clearly confirm the difference, from an epidemiological point of view, between chrysotile and amphiboles.
The effects of various asbestos fibers on health are well-known and documented. There is scientific consensus on the fact that fibers in the amphibole group are from 100 to 500 times more harmful to health than chrysotile, particularly for mesothelioma.
The confusion purposely maintained by opponents to safe chrysotile use is due to confusing two families of fibers, without distinction, despite the fact that the type, geological source, use and effects on health are radically different.
Concerning the very existence of a threshold, while there is no consensus about the level at which it is established the scientific community recognizes that this threshold does exist. Cohorts representing tens of thousands of workers exposed only to chrysotile at levels of concentration
Lower than 2 fibres/cm3 have been studied and clearly do not show an inordinate increase in disease in relation to general population.
Industrial diseases related to the use of asbestos are therefore the result of excessive and prolonged exposure to amphiboles. This is primarily why the ILO indicated that the asbestos issue is an issue of industrial hygiene, not a public concern.
Due to the latency period, cases of cancer or asbestosis observed today result from the past working conditions that no longer apply today.
It goes without saying that both the workers and employers of the chrysotile industry share the same objective as the WHO: the elimination of asbestos-related diseases. Nevertheless, its achievement must be in line with both the legal and scientific aspects, and reject the ban of chrysotile as the only responsible and acceptable option available.
The International Labour Organization (ILO) Convention № 162, Safety in the Use of Asbestos, provides for the safe use of chrysotile and cannot be used as a basis for a global ban.
As it was stated by the Employer members during 100 ILC conference in June 2011 “…the general prohibition of chrysotile asbestos (also called white asbestos) could not be construed from the relevant provisions of the Convention, which distinguished between the various types of asbestos…”(ILS Provisional record 18 Part two, page 106).
The ILO Convention No.162 specifically prohibits the use of crocidolite (blue asbestos) and products containing this fiber. Spraying of all forms of asbestos is also prohibited.
The ILO Convention № 162 is the key legal act on asbestos at International level. It provides for a set of risk management measures, including the safe use of chrysotile, the substitution and the prohibition depending on the fibre type, the circumstances in the workplace and the type of product manufactured.
By adopting laws and regulations that support the controlled use of chrysotile, regulatory authorities in the various countries demonstrate their concern for protecting the health and safety of workers, while ensuring that durable, inexpensive and completely safe products are available to consumers.
Moreover, these legislations and regulations are compatible with the principles put forth by the ILO and WHO.
The determination of many governments that have based their decisions on science rather than succumbing to industrial and political pressures must be noted.
Obviously it will be necessary and urgent to extend the measures adopted for chrysotile to all respirable industrial fibers whose risks (biological persistence) are greater than or equal to chrysotile. For all these fibers there must be true concerns about protecting the health of workers and the population.
Chrysotile should not be on the PIC list
Although many countries, including the Rotterdam Convention Member States, have repeatedly asked for a thorough examination of the facts,
— there has been no real scientific study undertaken evaluating the risk of using chrysotile under today’s controlled-use;
— there has been no comparative scientific evaluation performed on any of the replacement fibers for chrysotile.
— the lack of epidemiological data on the impact of chrysotile asbestos on human health
We do not even know whether or not any epidemiological studies on human health impacts have been conducted.
ITUM firmly opposes the listing of chrysotile asbestos in Annex III to the Convention on different grounds:
1. The poor quality of the notifications on the substance;
ITUM suggest that the Conference of the Parties recommend that the Chemical Review Committee resume its consideration of the chrysotile issue, taking into account all the scientific data on the chrysotile issue.
2. The lack of conclusive evidence of its harmful effects;
ITUM considers that the latest scientific evidence published, including numerous studies published in peer-reviewed scientific journals in the past decade alone, strongly supports the following views:
— Chrysotile is significantly less hazardous than the amphibole forms of asbestos;
— When properly controlled and used, chrysotile asbestos in its modern day high density applications does not present risks of any significance to public or worker health.
the lack of alternatives to the substance for its main uses;
the possibility that alternatives might themselves be harmful to human health.
An increasing number of scientists and governmental authorities have voiced concerns about the potential harmful health effects of some industrial substitute fibers and products proposed to replace chrysotile. The reason is that many substitute fibers or products have not been scientifically recognized as less harmful to health than chrysotile. Furthermore, in many instances there substitutes are less durable, are more expensive and very often of lower quality.
The unwarranted inclusion of chrysotile on the RC PIC list is just what some are waiting for to speed up the “total ban” crusade, and at the same time will give a strong boost to the marketing of substitute fibers and alternative products which are too often unregulated and rarely scientifically proven safer and less harmful than chrysotile. This underhanded scheme must be denounced. The fibers usually used to replace chrysotile, such as cellulose, aramid fibers and ceramic fibers, are more persistent in lung tissue and therefore potentially more hazardous to health. By prohibiting the use of chrysotile under the pretext of protecting workers, there is a chance of creating the reverse effect by promoting the development of unregulated fibers that are possibly more hazardous to the health of workers. Moreover, IARC only investigated a trivial number of alternative substances.
We consider that the use of chrysotile asbestos posed no risk to health when all safety standards are observed. In accordance with ILO Convention 162.
Numerous and recent scientific studies show that when chrysotile is mined and handled according to appropriate work practices as nowadays, it does not present an unacceptable lever of risk for the health of either workers or the general public.
We are quite sure that the advantages exist in developing countries of using chrysotile asbestos in specific applications, including roofing for low-cost housing, for which alternatives are of lower quality or more costly.
Inclusion of chrysotile asbestos into annex 3 of Rotterdam Convention would translate into the necessity for exporting and importing countries to extensively document all specific shipments of chrysotile from one country to another. This is not necessary, as chrysotile is a very well-known, naturally occurring substance, whose impact on human health has been extensively studied for decades. The companies that trade in chrysotile and the governments that regulate this trade in exporting and in importing countries know very well how to handle this substance safely. International transportation of chrysotile is already regulated by a stringent protocol and exporting companies are bound by agreements with their respective governments to export only to responsible users that can demonstrate they use it safely.
Workers in many countries fought long and hard to achieve safe and controlled use of chrysotile. They know how to use it in a safe manner and they intend to keep doing so.
The International Trade Union Movement for Chrysotile, representing hundreds of thousands of workers from the mines, mills and factories that produce chrysotile products, as well as the workers from the companies that support this activity, voice their strong opposition to the inclusion of chrysotile in Annex III of the Rotterdam Convention. These workers are primarily from countries such as Brazil, Russia, India, China, Kazakhstan, Ukraine, Kyrgyzstan, Canada, Mexico, Peru, Ecuador, Columbia, Bolivia.
Unnecessary administrative complications become trade barriers. The strongest proponents of inclusion of chrysotile in Annex III are avowed advocates of a complete ban on chrysotile. Most substances included in Annex III are eventually completely banned. The people of many countries would pay the biggest price. Not only would they loose the jobs involved in the mining, trade and manufacturing of chrysotile and chrysotile-bearing products, but the population would suffer because chrysotile products answer many of their essential needs such as sanitary infrastructures or housing.
Today a number of organizations are trying to confuse the world’s public opinion, stating that consensus has been achieved on the question of banning chrysotile asbestos. Our Trade Union Movement rejects such an approach. There is no consensus either in political, scientific or trade union circles. And despite the pressure on behalf of the European Union and organizations representing anti-asbestos lobby at COP Meetings to include chrysotile in Annex 3 of Rotterdam Convention, our International Trade Union Movement declares this to be unjust and discriminating for hundreds of thousands workers around the world.
We stand for the controlled use of chrysotile in accordance with ILO Convention No.162, and non-inclusion chrysotile into Annex 3 of the Rotterdam Convention.
The International Trade Union Movement for Chrysotile firmly follows the position of chrysotile safe use within the framework of decisions taken by highest decision making bodies of WHO and ILO concerning chrysotile and is strictly against inclusion of chrysotile asbestos into Annex III of Rotterdam Convention.