FAAM responds to ECHA’s recommendation on Asbestos Workplace Exposure Limits
The EU’s Chemicals Regulator, ECHA, has just closed consultations on a scientific report which will form the basis of the review of the occupational exposure limits (OELs) for asbestos fibres in workplace air.
In the midst of the Global Asbestos Awareness Week, the Faculty of Asbestos Assessment and Management (FAAM) the professional body supported by the British Occupational Hygiene Society, has issued a response, critiquing the science and highlighting some of the practical implications.
Over 45% of the estimated 12,000 people a year who die of work-related respiratory diseases have developed cancers or other diseases as a result of exposure to asbestos, which also places people in extreme vulnerability in relation to COVID-19.
While welcoming the study by ECHA as an important step in reassessing the OEL, an international panel of scientists, academics and industry professionals convened by FAAM, found the report to have scientific shortcomings and expressed concern over some of the practical implications of the approach that the report’s findings would necessitate.
For regulatory purposes, asbestos is a term that refers to six types of fibrous minerals, that were widely used in the past in over 3.000 products including for electrical, fire, sound and thermal insulation, as well as, for strengthening cements sheets and pipes, fillers, paints and plastics etc. Asbestos containing materials are still present in many homes and buildings in the UK, EU and throughout the world, although use of all forms in the UK has been illegal since 1999.
The experts highlighted a number of substantive assumptions and scientific errors in the Science Report. In particular, the EU request was to assess the six different types of asbestos minerals, but the report produced only one assessment for all the asbestos types. This will inevitably lead ECHA to recommend a single lower exposure standard for all forms of asbestos. While this may be apparently good news for workers at risk from exposure, the expert panel highlighted that this may actually result in worse protection for those involved in handling and disposing of asbestos.
The panel highlighted a number of areas that the implementation of a lower occupational exposure limit would be likely to have unintended consequences, for instance:
- The current method for measuring exposure is based on a world-wide standard and this may become unfeasible to continue to use in the EU and require more costly and time- consuming measurement methods.
- Large changes to the measurement method, and increased costs will lead to a reduction in the monitoring of worker exposure and even if monitored, the time it takes to determine whether the controls are sufficient.
- The amount of dust control necessary to reduce airborne emissions will require the development and use of improved technologies and their widespread deployment over many thousands of sites annually.
- Improved standards of respiratory protection such as widespread use of heavy and bulky self-contained breathing apparatus, may also be required.
- Large changes in methods, technology and costs can easily lead to increased levels of illegal removal, exposing workers and others to greater risks.
- Higher numbers of illegal removals will present a greater challenge for waste management, resulting in an increase in the existing problem of fly-tipping of asbestos wastes.
To limit these impacts, the practical issues of availability and implementation must be professionally and holistically evaluated across the asbestos management industry. This is something that BOHS is well able to do, through its specialist Faculty of Asbestos Assessment and Management, which brings together professional practitioners in a unique and focussed way.
Speaking on behalf of FAAM and the Society, Deputy Registrar, Jonathan Grant said
ECHA’s work in trying to protect workers is invaluable. The merit of the process used by Europe is that it does enable transparent critical feedback. We have highlighted important scientific and practical considerations, which need to be addressed if any subsequent decisions on the OEL are not to be seen as flawed.
BOHS CEO Kevin Bampton, an expert in Public Law, added, “It may seem counter-intuitive to be concerned about proposals to lower the legal minimum level of exposure to a toxic substance. However, imagine if a very low and identical speed limit was set for bicycles, lorries and cars – one that speedometers could not measure effectively while you were travelling. Would this lead to more people obeying the speed limit, people knowing whether they were under the limit and any fewer accidents? You would want to have a sound evidence base to address those questions before you made such a risky change. Our concern is that we want the best protection from this toxic substance for workers in practice.”
You can read the ECHA scientific report here.
You can read the scientific analysis by FAAM/BOHS here.