One can identify 3 stages in the regulation of major health hazards: a total ban, like a taboo in primitive societies; a forced reduction in the production of the hazardous substance to a level often just short of that which would bankrupt the industry, such as the “best available control technology” of the US Environmental Protection Agency (EPA); and a thoughtful risk–benefit analysis including comparative risk assessment.
A ban may well be the first approach to a very serious hazard. When a total ban is perceived as disruptive to society's overall goals, “best available control technology” might be the first approach. But when time is available, scientific and medical research can provide information useful for risk–benefit analysis. Perhaps there was good reason to argue for immediate, drastic action such as a complete ban when the asbestos problem first became widely known more than 30 years ago, but this was not done.
The EPA proposed a ban in 1979 on the manufacture of asbestos-containing products in the United States. Many of the questions raised by Jack Siemiatycki1 were asked and answered when a court of appeals remanded the matter back to the EPA in 1991 because they “failed to muster substantial evidence” to support their position that modern asbestos products present an unacceptable risk to the public.2 The EPA did not provide this evidence. We argue that it does not exist.
In calling for a complete ban now, the Collegium Ramazzini states, without evidence, that the risk of chrysotile asbestos is too great and that exposure cannot be controlled.3 On the contrary: exposures in the last 20 years seem to have been very well controlled. The increased rate of mesothelioma in the United States, which the Collegium uses to bolster its claim, occurs only among people old enough to have been exposed before 1970.
The Collegium argues, without proof, that all types of asbestos fibres present cancer risks so similar as to be indistinguishable. It ignores the characteristics, such as biopersistence and surface chemistry, that make some materials more carcinogenic than others. Yet it is these very characteristics that are needed to explain why substitutes such as synthetic vitreous fibres are safer.
The Collegium's approach to the health hazards of low-level asbestos exposure is behind the times. Because of its obsession with chrysotile asbestos, the Collegium has missed the really nasty hazards of the last half century, next to which the hazards of low-level asbestos exposure seem insignificant. The arsenic catastrophe in Bengal and Bangladesh is one example.
It is not too late to change. Let us urgently study the list of issues raised by Michel Camus4 and agree upon a proper comparative risk assessment.
References
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