The asbestos mining industry in Québec has been operating for more than 100 years. Its development and growth has had a very significant and beneficial effect on the economy of the surrounding communities, the province and the country. However, as it is nearly always the case, these benefits have not been achieved without some undesirable side-effects. As the mines grew, the members of the mining industry recognized early the fact that they must share the hard-won knowledge regarding preventive and control programs.
In the sixties, the industry embarked upon a program to bring all the mining and milling operations within safe limits. Some companies made their objective 50% of the permissible exposure limit values for chrysotile asbestos. This objective and the decision to protect the environment and people at work as well as at home were adopted as policy.
Corporate policy on this matter was clearly stated by the president and made known to all employees. Within each company, a senior manager was assigned responsibilities related to protection and prevention of occupational risk.
Each company had a joint health and safety committee that included representatives from management and employee representatives. In order to establish an action plan and respond to various problems, the following mechanisms were adopted by each committee:
€ a coordinator, named within management, reported to the president;
€ meetings were scheduled at monthly or quarterly intervals;
€ the committee reported on problem areas and ways to solve them, equipment, procedures;
€ following the committee meetings, the coordinator prepared a plan of action indicating the problem, a proposed solution, estimated completion time and costs.
One of their first tasks was to analyze and pinpoint areas of most concern. They prepared a layout of the plant with emphasis on areas with the most serious problems in visual airborne dust. A monitoring survey, including results of fixed and personnel stations, was also evaluated to provide a global picture of the plant.
Once the mines had established a plan of action, it was necessary to assign priorities to each problem based upon the amount of dust emission and the resources available. Identifying the principle problems and setting proper priorities are extremely important points to an action plan. Some guidelines used by the mines were:
€ setting-up a list of problems by degree of dust emission, starting with the highest;
€ choosing the highest contaminated area affecting the most employees and assigning it a high priority;
€ all items on the list with no cost should be implemented immediately. This usually applies to procedures, work habits, housekeeping;
€ obtaining approval for yearly monetary allocations from management;
€ providing estimate of the time required and costs of solving the problem.
At the asbestos mines, priorities were closely followed and updated as work progressed.
Based on the experience of the asbestos mining industry, situations will arise when the asbestos dust emissions exceed legislated limits. This cannot be tolerated. To prevent employees from being in a contaminated area, unacceptable situations must be addressed promptly. Because the health of the employees is of the utmost concern, the first step is to require all employees to wear appropriate respirators and personal protective clothing. However, personal protective equipment must be viewed only as an interim measure. The workplace environment must be made clean and appropriate engineering solutions developed and put in place.
The important role that workers have to play in achieving and maintaining clean and safe workplace environment were recognized at an early stage. Training programs were developed by joint health and safety committees and all employees were required to participate. And this was not a one shot effort. Employees were given training prior to the commencement of employment.
The industry was also committed to the professional development of its engineers and industrial hygienists. Their participation in specialized training programs enabled the industry to develop in-house expertise which permitted the development and implementation of state-of-the-art prevention and control programs.
When programs extend over several years, as was the case in the mining industry, it is important to divide the program into stages. The first goal should be to meet the regulatory limits. Depending on present dust emissions, the goal could aim for a reduction of 50% and subsequent goals could be a reduction of 20% until regulatory limits are met.
Even once regulated limit values are achieved, the job is not done. It is important to stay ahead of the game and anticipate pressure from government authorities to lower exposure limit values. It is therefore important to maintain an active research and development program to develop practical, low-cost solutions and to overcome any technological roadblocks which may be impeding progress in a certain part of the plant. Although mining is much different than product manufacturing, if the industry did not maintain a strong research and development effort to overcome some of the technical problems experienced in various parts of the mill, it is not clear that the mines would be in business today.
All of the companies engaged in mining and milling asbestos fibre in Québec are members of the Québec Asbestos Mining Association (QAMA). Although the companies are business rivals, they all share the common desire to protect employees and the communities from the potential risks association with their operations. In the sixties, the QAMA created an environmental control committee, where all the ideas were pooled and through which the combined knowledge of the industry was freely exchanged and put to work. To further strengthen this effort, the QAMA hired an engineer to guide the project.
The asbestos mining industry in Québec has recognized the need to adequately monitor the environment and members have combined their resources towards this end. Therefore, each mine experimenting with a new system has communicated the results to all other mines. They have agreed to open their doors to each other and to supply sketches and specifications. This prevents .the duplication of efforts and allows for a wider spectrum of research. Finally, the Association actively contributes to information exchanges among the various national and international technical committees.
Active involvement and the commitment of management, employees, engineers, maintenance workers and environmental inspectors resulted in solutions to difficult problems and substantial reductions of dust emission points throughout the plants. Often this was the result of sharing the hard-won knowledge among the member companies.
Now, to answer the first two questions you may have been asking yourself; Will it work?
You can see from the attached Graph 1 (average concentrations of asbestos fibres in the Québec mining industry) significant improvements can be accomplished over a period of time.
This same approach was employed by the asbestos producers to protect the communities from the undesirable features of asbestos mining operations. Active involvement and commitment has resulted in solving such difficult problems as air pollution associated with drying asbestos ore, disposal or tailings and dust created by the primary drills in the open-pit operation.
Results of these improvements aimed at providing clean air in the mining communities is clearly demonstrated on attached Graph 2.
As an industry, we have also learned that it is important not to be satisfied only with accomplishments achieved at our individual operations. To secure the long-term future of the asbestos industry, we have also realized that we must look downstream to our customers and to encourage them to look downstream to their customers and users of asbestos products. Like a steel chain, we are only as strong as our weakest link. And, if chrysotile asbestos or chrysotile asbestos-containing products are being misused or mishandled at any point of the product's life cycle, it could have long term repercussions for the industry as a whole.
In talking about prevention and control, it is therefore important to look beyond the plant gate. Your local industry association can be extremely useful in terms of developing and distributing information pamphlets, leaflets as well as coordinating your industry's public communications program. This may seem a burden, but chrysotile asbestos is not unique in this regard. Many industries are facing similar pressure and several have responded by developing aggressive product stewardship programs (PSP) The PSP adopted by the refractory ceramic fibre industry is quite pertinent and provides a fitting summary and conclusion for this information and training exercise:
11.2 - KEY ELEMENTS OF A PRODUCT STEWARDSHIP PROGRAM
1. Over time, a product stewardship program is likely to affect many aspects of your business. Insure that top management is committed to the program. Participation and input are needed from all levels in the organization, but if top management is not fully supportive, the program is unlikely to succeed. The basic rationale for product stewardship is rooted in fundamental attitudes on ethics and values. Top management must take the lead on such issues. Moreover, stewardship issues frequently cut across organizational lines making decentralized management difficult.
2. Create a "bias for action." Identify key portions of the program and get these underway promptly. There is generally ample time for mid-course corrections to the program as new data, facts and priorities emerge.
3. The list of possible activities of a PSP is long. Set priorities on possible initiatives. Identify short-, intermediate-, and long-range goals. Focus is important. Avoid setting goals that are ill-defined or excessively ambitious. Many published PSPs are so broad and full of generalities as to be useless in practical terms. Keep it relatively simple at first. An excessively broad program invites cynicism and ultimately, failure.
4. Where possible, identify and track quantitative measures of program effectiveness. Charts depicting time trends in these measures of effectiveness are good as visual indicators or program challenges and successes. If workplace exposures are particularly relevant, for example, then relevant exposure and concentration statistics should be tracked.
5. Be sure to emphasize communications in the PSP. Communications must be directed to employees, customers, regulatory agencies, and other constituents as necessary. Follow-up, where possible, to insure that these communications are being received and understood.
6. Be objective in assessing program results. A frank assessment of failures as well as successes is ultimately in everyone's best interest. Regulatory agencies and others may be critical of failures, but you will gain credibility and trust for having brought these to their attention.
7. Involve your customers. Without their full support, no program can be truly effective. Seek to organize similar programs among your customers. Customers always appreciate technical service, and a good PSP is a way to build customer loyalty. Moreover, customers can often contribute useful ideas to a PSP.
8. Products and processes that have potentially adverse health, safety or environmental effects are likely to be regulated. Accept this premise and be pro-active in dealing with regulatory agencies. The lessons learned as a result of stewardship activities should enable you to suggest economically efficient control alternatives. Unless you feel strongly that proposed regulations are arbitrary and capricious, do not waste time and effort with adversarial behaviour.
9. Use objective outside advice to the extent needed. Attorneys, consultants, and other specialists can make useful and sometimes pivotal, contributions to the design and management of a stewardship program. But, do not cede ownership of your program. The long-term success of your program is critically dependent on in-house personnel. Assign some of your best personnel to the PSP. This not only insures that good ideas are available, but underscores your commitment to the program.
10. Stress continual improvement in measures of program effectiveness. A compliance-based approach can be effective, but an emphasis on continual improvement is preferable.
11. Audit results of the PSP and use results of these audits to restructure the program. Quantitative measures (see point 4) of program performance and definable goals are easier to audit.
12. Related to the above point, if audits or other emerging developments show negative results, do not seek to punish those responsible. Instead, look for constructive solutions to problems. Be mentally prepared for adverse developments. Progress is not always continuous. Problems, when found, do not always indicate that things are getting worse. Rather, these may reflect the fact that you are aggressively searching for them.
13. Identify and try to maintain a dialogue with potential critics. Vocal critics are often difficult and irritating to deal with. However, it is a capital error to disregard their concerns. Use meetings with critics to define areas of common ground as well as points in dispute. Try to understand their point of view.
14. Make bold decisions when these are called for. Withdrawing a product line or making a substantial capital investment, for example, could be painful choices - but well worth the price if they can ensure the protection of worker health and safety and the survival of the business.
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