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Priority Existing Chemical Assessment Reports - Chrysotile Asbestos
1.1.1 CHEMICAL IDENTITYChemical nameChrysotile is listed on the Australian Inventory of Chemical Substances (AICS).
Other names
Trade names
1.1.2 APPLICANTSBendix Mintex Pty Ltd Richard Klinger Pty Ltd Vivacity Engineering Pty Ltd 1.2 EXTRACT FROM FULL PUBLIC ASSESSMENT REPORT (CHRYSOTILE ASBESTOS - PEC9)1.2.1 DISCUSSION AND CONCLUSIONSScope of the assessmentThis report has focused on: the occupational, public health and environmental risks associated with current uses and applications of chrysotile in Australia. In particular, the assessment has focused on the importation of chrysotile for manufacture of friction products and gaskets together with the use of these products in a variety of 'down stream' industrial/occupational sectors. Also assessed was the use of chrysotile as an additive in a specialty epoxy resin adhesive. Assessment information was obtained from a number of sources. Information on imports/exports of raw asbestos/chrysotile and products were obtained from Australian Customs Service (ACS) and Australian Bureau of Statistics (ABS). Data (including exposure monitoring, production process details, risk management strategies and copies of labels and MSDS) were provided by Applicants (i.e., manufacturers of chrysotile products) and end users (in particular the Automotive and Aircraft industries). Much of the information on end use of friction products and gaskets and substitute (alternative) products was obtained from a NICNAS 'Automotive Aftermarket Survey' which incorporated an exposure monitoring study carried out by ASCC. Information on Australian and overseas regulation/legislation was obtained through a NICNAS commissioned consultancy, which included an evaluation of mechanisms for restricting uses and importation of chrysotile-containing products. Current use in AustraliaOver the past 15-20 years, asbestos consumption worldwide has generally declined, especially in the US and European markets. In Australia the mining of asbestos (all forms) ceased in 1983. Asbestos (all forms) has not been exported from Australia since 1984. Chrysotile is the only form of raw asbestos being imported into Australia (by 3 companies) and has remained at approximately 1-2 thousand tonnes per year over the past decade, Canada being the sole source of these imports. Despite the increased importation of non-asbestos products over the past few years, imports of asbestos (assumed to be mainly chrysotile) products, particularly friction products and gaskets, do not appear (see section 5.2.3 for qualification) to be declining. Asbestos is still present in the general Australian community from a range of past uses, which have been carried out for substantial periods of time. However, assessment of exposure from past uses was considered outside the scope of this PEC Report as they are adequately dealt with by local government authorities and under existing regulation and controls. Examples of some of these past uses are provided in Section 5 of this report. In Australia imports of raw chrysotile are used mainly in the manufacture of friction materials and CAF sheeting for gasket production with a small quantity being used in the manufacture of a 'non-sag' additive in an epoxy resin adhesive. All these uses, according to manufacturers, are being phased out. Brake linings and gaskets were found to be the main asbestos products imported for use in Australia. Most clutch facings (approximately 99%) for both automotive and industrial applications are now asbestos free. Chrysotile brake linings are imported for industrial applications and use in passenger motor vehicles, although most linings imported for these applications are non-asbestos. The use of brake blocks in Australia is declining; the predominant use of which was found to be for industrial applications (e.g. railway industry and mining equipment). A significant percentage of these brake blocks are non-asbestos. Customs data do not permit differentiation between asbestos and non-asbestos gaskets. Investigations indicated that a significant number of non-asbestos gaskets are being used for industrial applications, however there continues to be large numbers of asbestos gaskets still used. A small number of 'one-off' uses for asbestos products were also identified. These products include blades in high vacuum pumps, asbestos yarn in packing, asbestos gloves and asbestos washers for oil flame safety lamps (used by miners). Investigations indicate that importation of asbestos fibre cement products is very unlikely. In the new vehicle importing and manufacturing industries only one company reported the use of asbestos 'original' equipment (in two of their current models). The remaining companies surveyed, used non-asbestos original equipment. The majority of these companies reported that they have policies in place regarding not using asbestos products. The majority of industrial equipment and machinery, such as agricultural machinery, have non-asbestos original equipment. A significant number of these companies use non-asbestos parts in both superseded and new equipment and machinery. Most of these companies stopped using asbestos parts in the late 1980s. In the aircraft industry asbestos parts are still being used in new and older aircraft (e.g., gaskets and seals). However, in this industry there is a continued effort towards the identification of possible substitutes. Effects of concernChrysotile is a known human carcinogen and has been classified as such by ASCC. As with other forms of asbestos, chrysotile can cause asbestosis, lung cancer and mesothelioma in humans and animals in a dose related manner. The Australia Mesothelioma Program reports that Australia has the highest incidence of mesothelioma in the world (Leigh et al., 1997). Controversy exists over the potency of chrysotile in relation to other forms of asbestos (crocidolite, amosite and tremolite) and whether asbestosis is a prerequisite for cancer and hence, whether a level of exposure for chrysotile exists, below which there would be no risk to human health (i.e., an exposure threshold for carcinogenic effects). As such, linear extrapolation methodology has been used to provide a conservative estimate of risk. Risk estimates for lung cancer in workers appear to be dependent on both cumulative exposure and the type of industry where exposure has occurred. ASCC (ASCC, 1995a) has estimated the lifetime risk of lung cancer, based on the best available epidemiological data (from friction products industries overseas) as up to 173 additional cancers per 100,000 workers exposed to a daily average of 1 chrysotile fibre per mL. Extrapolation for lower exposures provides lifetime risk estimates (per 100,000 population) of 86 and 17 for exposure to 0.5 and 0.1 f/mL, respectively, although estimates by US NIOSH and OSHA are between 4 and 30 times higher (Lash, 1997; Stayner et al 1997). There are many confounding factors surrounding risk estimates for chrysotile exposure, the most important of which are; the possibility of a threshold effect, possible co-exposure to other fibre types, inaccurate estimates of historical exposures and the influence of tobacco smoking. Conclusions by scientific experts in a recent consensus report (see section 10.2.1) were: that all asbestos fibres can cause mesothelioma, but amphiboles are more potent carcinogens for the mesothelium; that low level exposure to asbestos is sufficient to cause mesothelioma; that cumulative exposure to 25 fibre-years (fibre.year/mL) is sufficient to cause lung cancer and that asbestosis is not a necessary prerequisite for lung cancer. Exposures arising from current useOccupationalExposures of most concern are those where friable chrysotile may be generated. Occupational exposure may arise from the manufacture of CAF sheeting and other products (mainly friction products) and during processing and end-use (replacement) of these products, where public exposure may also occur. The major route of exposure is inhalation. Air monitoring data were provided by the two producers of chrysotile products, Bendix Mintex and Richard Klinger. Data for the period 1992 to 1997 (for Bendix Mintex), indicated that more than 80% of personal samples were less than 0.1 f/mL. Only 2 samples during this period exceeded 0.5 f/mL. Monitoring data (1991-96) at Richard Klinger (Perth site, where raw chrysotile is handled), indicated that approximately 60% of the personal air samples were less than 0.1 f/mL, with only one sample exceeding 0.5 f/mL. Personal and static samples for the years 1989, 1991, 1993 and 1995 at Richard Klinger (Melbourne site, where production of gaskets takes place) were all less than 0.05 f/mL (static exposures below 0.01 f/mL). Air monitoring data from other sources were also assessed, which included an automotive aftermarket survey of service garages in Western Australia where exposure levels were found to be less than 0.1 f/mL. Vivacity Engineering, who manufacture an epoxy resin adhesive containing chrysotile, has not conducted air monitoring during manufacturing processes. However, once in place, the hardened adhesive is not considered to be of concern. The NICNAS Automotive Aftermarket Survey showed that exposure to friable asbestos is highest in the brake bonding industry during grinding of brake shoes and cutting of brake linings. The highest personal monitoring result obtained was 0.16 f/mL, during machining of brake shoes. Work in the brake bonding industry is declining due to the availability of brake pad and clutch kits (preformed to standard sizes) which do not require modification before installation. However it was reported that 90% of current activities in this industry sector involve asbestos-containing material. International monitoring results in service garages indicated exposure levels were generally below 0.2 f/mL. Data for personal and static short-term sampling in workshops involved in the removal (wet) and replacement of asbestos gaskets were <0.05 and <0.03 f/mL respectively. However, higher exposure levels were noted during the 'dry' removal of gaskets (up to 1.4 f/mL). Both national and international data indicate that present exposure levels are lower than in the past. Reduced exposure levels could be due to increased awareness of the hazardous effects of chrysotile among workers and/or due to implementation of regulatory controls and better work practices (e.g. prohibition of use of compressed air to blow asbestos dust and diminished use of grinders) during brake and clutch servicing. Monitoring results also indicate that over the past decade, the majority of exposures were below the current ASCC national exposure standard (1 f/mL) for chrysotile (this standard is under review - see section 13.5). However, it should be noted that this standard relates to exposures where chrysotile is the only asbestos fibre present. Where other forms of asbestos (e.g., amosite or crocidolite) are present or where the composition is unknown, the ASCC TWA exposure standard is 0.1 f/mL (ASCC, 1995d). PublicThe major source of public exposure is from chrysotile dusts generated by vehicle braking, although the level of exposure is very low. Overseas and Australian studies showed very low air levels of chrysotile fibres at busy intersections (less than 0.01 f/mL) or freeway exits (0.5 particles/mL), generated by braking vehicles. At a location of 30 metres from the nearest traffic, air levels were below the limit of detection. There are no data on exposure of home mechanics during the changing of brake pads and shoes. However, the time-weighted exposure of home mechanics is unlikely to be higher than that of workers in automotive brake service centres. EnvironmentWhen chrysotile is encapsulated in end use products such as brake linings and epoxy-resin adhesives, it is unlikely that fibres will be in a form where an environmental hazard is posed. Based on available data for Australia, it can be predicted that the manner of use of chrysotile (including release from driving and wastes from manufacturing) as outlined in this report, will result in a low exposure and hazard to the environment. Current regulation and risk managementAustraliaIn Australia, legislation is currently in place that restricts or controls activities involving use of asbestos. Chrysotile is regulated (usually under the definition of asbestos) through various State/Territory regulations relating to dangerous goods (transport), OHS and the environment. In addition, local governments have specific requirements for building and construction work involving asbestos. Current prohibitions on use/importation of asbestos and products relate solely to other asbestos types (mainly amphiboles), and in some cases specifically exclude chrysotile. In addition, the extent to which asbestos products (articles) are regulated under current legislation is often unclear due to differences in definitions (e.g., asbestos material, and asbestos process). Chrysotile is regulated in the workplace under hazardous substances legislation enacted by the Commonwealth, States and Territories. This is based on the ASCC Hazardous Substances Model Regulations, which address issues/requirements such as control measures, labeling, MSDS, exposure standards, classification and scheduling and health surveillance. The ASCC national exposure standard for chrysotile is 1 f/mL, however the States and Territories have not uniformly adopted this. In March 1993, ASCC noted information in a report on the levels of lung cancer risk presented by chrysotile and its application to various industries. Since this time the national exposure standard for chrysotile has been under review 1 (with public comment sought on proposed standards of 1 f/mL, 0. 5 f/mL and 0.1 f/mL). From the exposure data gathered, it can be concluded that OHS control measures are available to control exposure to below current national and State/Territory exposure standards. In the majority of workplaces studied, measured exposures were at or below 0.1 f/mL2 . Deficiencies were noted in MSDS and labels (for both raw chrysotile and products) with regard to ASCC requirements, particularly in regard to labeling of imported products, where in some cases labels did not state that the product contained asbestos material. Induction training and health surveillance were also considered inadequate in some workplaces. With respect to health surveillance, new developments in diagnostic methods, as highlighted in the Helsinki criteria (Anon, 1997), need to be considered by ASCC with respect to their current requirements (ASCC, 1995c). Other relevant ASCC risk management activities include discussions with NHMRC in relation to prevention and treatment of asbestos-related diseases and the development of a strategy (in consultation with State/Territory jurisdictions) for dealing with asbestos-related diseases, which will include further research requirements (Labour Ministers Council, 1998). With regard to road safety, regulations/standards are in place in a number of States and Territories (made under the Road Safety Act, 1986 and the Motor Vehicle Standards Act 1989) relating to the quality/testing of friction products. Examples are the Australian Design Rules, developed by the Federal Office of Road Safety (FORS) and the Australian Standard for the Evaluation of Aftermarket Disc Pads for Passenger Vehicles (Standards Australia, 1997). OverseasA number of initiatives have been undertaken at the international level to regulate asbestos use and exposure, the most notable of which are the EU Directives on the marketing and use of asbestos, which contain specific prohibitions on the use of certain chrysotile products and certain work practices. Other initiatives include the ILO Convention 162 and the Helsinki criteria that aim at providing a framework for policies to protect worker health and for recognition, attribution and screening for asbestos related diseases. The majority of countries regulate use of asbestos and asbestos containing products. Current regulation/legislation was assessed from 13 countries. As with Australia, none of these countries have implemented absolute bans on chrysotile or chrysotile products, as relevant legislation in most countries contains either specific exemptions for certain classes/types of products or general exemptions whereby government authorities may grant exemptions on application. In most countries assessed, vehicle manufacturers are using asbestos-free parts for new vehicles and use in older vehicles is subject to phase-out regulations. Chrysotile products are the most common exemptions in the regulations (on asbestos) assessed and friction products and gaskets are the most common class of product exempted. Most exemptions for these products are either for a prescribed period of time and/or are subject to the development/availability of suitable (i.e., safe performance and lower health hazard) alternative products for specific applications. AlternativesNICNAS surveys on the use of asbestos alternatives indicated that substitution is occurring in many industries and at a quickening pace. In Australia, chrysotile has been replaced for many uses, which include railway blocks, cement sheeting, tubes and piping, roofing tiles, and fibre insulation/packing. The NICNAS Aftermarket Survey found that the automotive industry is moving rapidly towards using non-asbestos products (friction products and gaskets) with almost all new vehicles now asbestos free. Replacement non-asbestos parts are reported to perform as efficiently or better than asbestos parts (Baker, 1992). However, Bendix Mintex has advised that their testing results indicate that a number of sub-standard alternative products are being introduced to the Australian market, mainly from non-Japanese Asian sources. Non-asbestos parts are also available for some superseded models and clutches. With respect to older vehicles fitted with 'asbestos original' equipment, the suitability and efficacy of using non-asbestos replacement parts was difficult to ascertain, due mainly to the fact that the testing of non-asbestos parts in most old vehicles is reportedly costly and hence limited. However, other countries would also have faced this issue during phase-out of chrysotile friction products, which should expedite the development of suitable alternatives. Bendix Mintex indicate that they have a product range of non-asbestos brake linings which covers around 90 per cent of vehicle models in Australia, however the extent of coverage for the remaining market by other suppliers of alternative friction products was not ascertained. In order to evaluate current and future use of asbestos products in the aftermarket, an assessment of the age of vehicles in use in Australia compared to other countries was carried out. In a recently available survey it was found that Australia has the highest percentage of cars older than 10 years, which may account for the sustained importation and use of chrysotile products in the automotive industry. Other explanations for continued use (of asbestos products) are the cost differential between asbestos and non-asbestos products and the fact that there are no regulations aimed at preventing replacement of non-asbestos with asbestos parts in the aftermarket. Bendix Mintex also reports that preferences exist for asbestos products based on 'driver perception' of performance. Investigations also revealed that in some industries, asbestos gaskets are still used reportedly because no alternatives currently meet the use requirements. For example it is reported that no substitutes have been developed to withstand high temperature and high-pressure conditions for gasket use in the petrochemical industry. Therefore there is also a need for further research into substitutes for asbestos gaskets. A considerable amount of information on alternatives was reviewed in this assessment. The International Programme on Chemical Safety (IPCS) and the European Union have also conducted reviews of alternative fibres. The reports of these bodies provide significant data on the safety of alternatives. There are alternatives that are considered to be safer than chrysotile. However there is a potential that alternative fibres which have similar physical properties (particularly fibre dimension) to chrysotile may exhibit similar toxicological profiles. Therefore further work is required to generate health effects data for proposed alternative materials. Replacement of chrysotile with other substitute materials must take into consideration all available toxicological, physicochemical and performance data to ensure that the selected substitutes are likely to present lower health risks than chrysotile for each particular use, without compromising road safety. 1.2.2 RECOMMENDATIONSPreambleThis section provides the recommendations arising from the PEC assessment of chrysotile. Recommendations are directed at regulatory and non-regulatory bodies and users of chrysotile products. In order to facilitate consideration of these recommendations, the following provides a summary of the critical issues to be weighed. These should form the basis of a balanced action plan.
RecommendationsRecommendation 1: Phase-out (importation and local manufacture)It is recommended that the uses of chrysotile in Australia, including manufacture for the purpose of export, be phased out over time, with the period of phase out to be determined by the relevant regulatory authorities. In achieving this it is further recommended that: a) Specific phase-out periods should be set, with stages (over the shortest possible period of time) to encourage and reflect the availability and suitability of alternatives. b) Action is taken in the immediate future to prohibit the replacement of worn non-chrysotile original equipment with chrysotile products, as alternatives are now available. c) No new uses of chrysotile or chrysotile products should be introduced (i.e., an immediate prohibition on new uses). d) Occupational health and safety authorities take the lead role in considering this recommendation and specific strategies to implement it as worker health is identified as the major concern. This role would require involvement of other relevant authorities, including road safety authorities. e) That NOSHC consider use of the existing hazardous substances control framework in order to avoid adding to the numerous existing pieces of regulation for asbestos. This would enable controls over both supply and workplace use. It would also enable any necessary Regulatory Impact Statement (including road safety issues) to be undertaken. This mechanism would need to be supplemented by controls over supply for public use by the relevant authorities. To facilitate any phase out it is further recommended that: f) Substitution of chrysotile by less hazardous materials is facilitated by dissemination of information to industry, workers and the public about suitable alternatives for specific uses. In particular, it is recommended that data on performance testing be obtained by importers/distributors of alternative friction products prior to release of any new products into the Australian marketplace. In this respect, industry bodies can make a significant contribution to the recommended phase-out. g) The assistance of the Australian Customs Service and Australian Bureau of Statistics is sought to identify necessary changes required for compliance as currently, there are shortcomings in the customs coding of imported chrysotile products. This would include improvements to enable distinction between asbestos and non-asbestos materials, for all categories of products and to reduce the possibility of misclassification. Consideration should also be given to using similar tariff classifications/codes for exports and imports. h) Activities are initiated to promote maximal use of non-asbestos friction materials where these have been specifically identified as substitutes. To facilitate this, guidance information should be made available for chrysotile original equipment vehicles (as with new vehicles) which should include details of suitable non-asbestos friction materials. Participation of the manufacturing and aftermarket industry, insurance companies and motoring organisations in such activities would lead to a more extensive penetration of the aftermarket. Recommendation 2: ASCC Hazardous Substances FrameworkIt is recommended that a number of areas of the ASCC Hazardous Substances Framework, which includes the Model Regulations for the Control of Workplace Hazardous Substances, be considered for review and update, as follows: a) Classification. Prior to publication of this report the EU updated its classification for chrysotile, replacing R45 (may cause cancer) by R49 (may cause cancer by inhalation). This revised classification is supported and its inclusion in the ASCC List of Designated Hazardous Substances will need to be adopted by ASCC according to the usual process. b) Exposure standards. It is recommended that ASCC consider this report in the context of its current review of the exposure standard for chrysotile. In particular noting, (i) for health hazards, that there is considered to be no safe level of exposure to chrysotile, and (ii) the exposure data collected for this report from Australian workplaces. Priority consideration should also be given to the development of standards for asbestos alternative materials that do not have a national exposure standard, and maintenance of exposure standards where they already exist. In particular, for alternative fibres that are currently being used in friction products and gaskets. c) Methodology for fibre analysis. In conjunction with consideration of the exposure standard, noting that the analytical methods differ in their level of detection of chrysotile, it is recommended that the adequacy of the current standard method of analysis should be considered. This may be required to support any change in the exposure standards for chrysotile and/or alternative fibres. d) Health surveillance guidelines. It is recommended that ASCC review these guidelines to ensure they are up to date with current knowledge on detection of chrysotile-related health effects in workers. e) Carcinogen regulations. Consideration of any phase-out recommendation (see Recommendation 1) will require update and review of the current scheduling of chrysotile in Schedule 2 to the Model Carcinogenic Substances Regulations. Recommendation 3: Implementation of Workplace controlsIt is recommended that manufacturers, suppliers and users comply with the requirements of the ASCC Hazardous Substance Model Regulations, as adopted by States/Territories, in particular: a) Classification. The review confirms the current classification of chrysotile as a carcinogen category 1 (R45), with danger of serious damage to health from prolonged exposure (R48), as listed in the ASCC List of Designated Hazardous Substances. However note the foreshadowed change in Recommendation 2a) above. b) MSDS. Noting major inadequacies in some existing MSDS, MSDS should be updated and reviewed to comply with requirements. This should include ensuring that adequate information is provided on ingredients, health hazards, the Australian exposure standard, personal protective equipment, safe handling and disposal and contact details for further information. Where MSDS are not provided for chrysotile products, sufficient information on hazards, safe handling and precautions for use must be present on the label and/or supplementary information (e.g. information sheets) present in the product packaging. The latter approach would also ensure adequate information for use by the general public, where MSDS would not be required by legislation. c) Labeling. Noting the inadequacies of labeling identified in this assessment, labels should be reviewed and updated to ensure they comply with requirements. In accordance with the Model Regulations, this is a duty of the manufacturers and importers. In the workplace, if it is not clear whether a product is asbestos or non-asbestos, procedures must be in place to ensure that the product is handled as if it were asbestos and labeling solutions should be sought to assist identification of types of hazardous fibres present. This is particularly relevant for the aftermarket industry, due to the need to remove and dispose of worn parts and in some cases to further process replacement parts (e.g. brake bonding). d) Exposure monitoring. Should be continued to enable exposure to be reduced to the minimum feasible level and in accordance with the relevant exposure standard. This includes those applications of asbestos/chrysotile identified in this report where little if any exposure monitoring data were available. In conjunction with review of the ASCC national exposure standard for chrysotile, it is recommended that relevant State/Territory and other Commonwealth regulatory authorities provide advice on the work situations were exposure monitoring is indicated. This will be dependent on the standard set, and should also take into account the representative exposure data provided in this report. In addition, applications where workers are potentially exposed to alternative 'non-asbestos' fibres should also be monitored, with regard to compliance with exposure standards (ASCC 1995d). e) Engineering controls and safe work practices. It is recommended that the current controls and practices in workplaces be reviewed and updated, in order to eliminate, wherever possible, exposure in the workplace. f) Health surveillance. It is recommended that health surveillance be carried out in accordance with the ASCC Health Surveillance Guidelines for 'chrysotile'. g) Training. It is recommended that those employees who are potentially exposed to chrysotile are provided with an adequate induction and training program, which should incorporate:
Recommendation 4: Public health and safe disposala) Continued progress towards a phase-out of chrysotile in favour of less hazardous materials is supported. This phase out should be conducted with care so that greater risks to road safety are not introduced through inferior performance of substitute materials. a) It is recommended that a warning be carried on the label/packaging of brake pads/shoes containing asbestos/chrysotile that are available to the public for 'do it yourself' repair and maintenance. A suggested wording is as follows: Warning - this product contains asbestos. When exchanging brake pads/shoes, do not inhale brake-housing dusts. Do not blow or use compressed air to remove dusts from the housing, as repeated exposure to the dust may cause lung disease, including cancer. b) Risk management options need to address disposal of used chrysotile containing products (e.g., provision of re-sealable bag - for disposal of old parts - could be enclosed with asbestos friction products available to consumers). Recommendation 5: Environmental disposal measuresDisposal of used asbestos parts to standard municipal landfills is acceptable. However it is recommended that all workplace asbestos waste be collected and disposed of by licensed hazardous waste contractors. It is recommended that handling of chrysotile waste and disposal of used chrysotile packaging is in accordance with the following: a) For friable asbestos/chrysotile collected under dust extraction techniques: Waste collected under dust extraction methods should be put in properly labeled translucent bags (polyethylene) with a minimum thickness of 100 microns. Bags should be sealed immediately after filling, and stored in an area where they cannot be broken or otherwise disturbed. They should be collected and disposed of by a licensed hazardous waste contractor. b) For waste bags of imported raw chrysotile: Sacks or bags which contain loose asbestos fibres, or mixtures including loose asbestos fibres, should be deposited in a suitable receptacle, under a dust extraction hood immediately after being emptied. Where possible, the bags should be shredded and recycled in the process. For disposal, bags should be sealed in an impermeable outer bag and deposited in an appropriate landfill. A further method of plastic bag disposal is melting. By melting the empty bags and wrappers, the asbestos residue becomes embedded in the melted plastic. Under no circumstance should bags be reused for packing or other purposes. Recommendation 6: Public InformationIt is recommended that appropriate measures are taken to disseminate information in order to provide information to the community with regard to issues addressed in Recommendations 1b, 3, 4 and 5. Suggestions on this issue in the public comment phase for the draft PEC report were that such measures could be addressed in a campaign facilitated by participation of unions, industry, motoring associations and health authorities. The type of activity required will be dependent on the risk management action to be implemented. Recommendation 7: Secondary notificationThe National Industrial Chemical (Notification and Assessment) Act 1989 prescribes circumstances where secondary notification is required. Examples are provided in Section 12 of this report. Recommendation 8: Data gaps and further studies/research requirementsIn general, the following research is strongly supported: a) It is recommended that research into alternatives to chrysotile should actively continue, taking into account the need to ensure that the relevant hazard information is generated to ensure that proposed alternatives present reduced risks to health and the environment. b) At present it is not possible to identify a level of chrysotile exposure below which there would be no risk to human health. Further information on this, including full elucidation of the mechanism of action for chrysotile induced lung disease and mesothelioma, would assist regulatory decision-making. |
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