The Report of the Royal Commission on Asbestos recommends that the use of crocidolite and amosite asbestos be prohibited in Ontario manufacturing activity. It recommends that a like prohibition apply with respect to the use of chrysotile asbestos in textile manufacturing. As for the use of chrysotile asbestos in other types of manufacturing, the Commission recommends a control limit of 1 asbestos fibre per cubic centimetre of air, abbreviated as 1 f/cc. How does this approach to the regulation of asbestos in so-called "fixed place industry," that is mining and manufacturing, compare to regulations enforced or proposed elsewhere?
In the United States, which is currently the scene of multi-million dollar lawsuits launched on behalf of thousands of workers disabled or killed by high levels of asbestos exposure twenty or more years ago, a control limit of 2 f/cc has been enforced since 1976. This control limit has been criticized as being far too high by the United States Government's National Institute for Occupational Safety and Health (NIOSH). In 1976, NIOSH recommended a control limit of 0.1 f/cc for all types of asbestos in all types of industrial settings. In the autumn of 1983, the U.S. Government's Occupational Safety and Health Administration (OSHA) invoked an emergency standard, since stayed by court order, of 0.5 f/cc. This 0.5 f/cc control limit would also be applicable to all asbestos types in all industrial settings.
The United Kingdom, unlike the U.S., has applied different regulations to different types of asbestos. At present, the use of crocidolite asbestos is prohibited, with a nominal control limit of 0.2 f/cc being attached to this type of asbestos. Amosite asbestos is subject to a control limit of 0.5 f/cc, and chrysotile asbestos is under a control limit of 1 f/cc. Effective next summer, the U.K. will place chrysotile asbestos under a control limit of 0.5 f/cc. While the U.K. applies different regulations to different types of asbestos, its regulations do not take account of the possibility that a given type of asbestos may be more hazardous in certain industrial uses than in others.
The approach taken by the Ontario Commission to asbestos regulations in industry breaks new ground because it calls for regulations that will differentiate between the different risks posed by the same type of asbestos in different industrial settings. The type of asbestos involved, chrysotile, is the only type that has actually been used in Ontario manufacturing since 1980.
The Commission finds, on the basis of evidence which includes sworn testimony from an international who's who of asbestos experts, that the use of chrysotile asbestos in textile manufacturing creates starkly higher risks of worker disease and death than the use of chrysotile in other kinds of manufacturing processes. According to the Commission's findings, the most hazardous asbestos fibres are those that are long and thin. Because the manufacture of asbestos-containing textile products involves spinning and weaving, this process if far more likely to generate long, thin fibres than other manufacturing processes. After examining the evidence, the Commission estimates that textile manufacturing with chrysotile asbestos exposes workers to risks twice as great as work with amosite asbestos. The Commission therefore concludes that the use of chrysotile asbestos in textile manufacturing should be prohibited in Ontario. No significant textile manufacturing operation currently uses chrysotile asbestos in Ontario.
In Ontario at present, chrysotile asbestos involves about one thousand workers, mainly in the manufacture of automotive brakes. A less significant volume of manufacturing activity uses chrysotile asbestos in the fabrication of products like gaskets and packings. Because these kinds of manufacturing activities mean that chrysotile asbestos is either ground to fine dimensions or encapsulated in liquids early in the manufacturing process, a much smaller volume of long, thin fibres can become airborne. Worker risks are correspondingly reduced. Therefore, the Commission recommends that chrysotile asbestos in friction product and general manufacturing other than textiles be subject to a control limit of 1 f/cc, and thereby endorses the existing Ontario control limit.
Because current and proposed U.S. control limits do not distinguish among different types of asbestos, and for that matter between different manufacturing processes, they leave workers exposed to a range of risks from crocidolite, from amosite, and from chrysotile asbestos in textile manufacturing, which the Ontario Commission finds unacceptable. According to the Commission's calculations, even the NIOSH recommendation of 0.1 f/cc control limit for all asbestos types is too lax for crocidolite and for chrysotile in textile manufacturing. In any event, the Commission expresses the opinion that current measurement technology does not permit the effective application of a 0.1 f/cc control limit. When the health risk to workers requires a control limit that is below measurement capacity, the substance should be prohibited, the Commission states.
As for the 0.5 f/cc control limit that will soon become applicable to chrysotile asbestos manufacturing in the U.K., this regulation encompasses the textile manufacturing which the Ontario Commission has deemed sufficiently hazardous to warrant outright prohibition. As for the Commission's 1 f/cc control limit in general chrysotile manufacturing, this maximum is to be applied through recommended techniques and enforcement methods to assure that the average worker exposure will be 0.5 f/cc.
In Canadian provinces other than Ontario, the most common control limits are 2 f/cc for chrysotile, 0.5 f/cc for amosite, and 0.2 f/cc for crocidolite. Québec applies a standard of 2 f/cc, with an additional limitation on the total mass of asbestos concentration in the air.