At a NIOSH hearing this week, the American Society of Safety Engineers (ASSE) submitted testimony outlining its concerns on the proposed NIOSH “Research Roadmap on Asbestos and Other Elongated Mineral Particles (EMPs),” noting that it would divert from its ultimate goal of protecting workers, according to an ASSE press statement.

The concern centers on the definition of what "fibers" constitutes a "risk" to workers when it comes to asbestos, and, the possibility of moving forward and wasting public health resources as well as possibly misleading regulators in the future in a way that could adversely impact public safety and health by minimizing the effects of true asbestos on workers or the public, according to ASSE.

ASSE professional member of its Mining and Construction Practice Specialties Adele L. Abrams, Esq., CMSP, noted in her comments at the hearing, “ASSE is concerned that the revised NIOSH Roadmap has diverted from its ultimate goal in the original draft of developing a unified theory of thoracic-sized fiber toxicity between (1) currently-known and newly identified mineral fibers; (2) synthetic vitreous fibers (SVFs); and (3) nanofibers. In fact, we understand that NIOSH representatives stated during a public meeting that the February 2007 Roadmap held the unified theory as the “ultimate goal” of its research.

“Yet, in the revised draft Roadmap, NIOSH now downplays this unified theory by stating, ‘The extent to which a policy concerning thoracic-size EMPs could be extended to SVFs and even to other manufactured materials such as engineered nanomaterials, would need to be explored’,” Abrams said. “ASSE believes the February 2007 draft Roadmap had already explored a unified theory concerning thoracic-size fibers and had clearly proposed a policy concerning a unified theory as its ultimate goal.”

Abrams noted that ASSE is troubled that the revised Roadmap does not provide an adequate explanation for why NIOSH is backing away from important research on a unified and coherent risk management approach that fully incorporates this unified understanding of the toxicity of mineral and manufactured elongated particles that could then be developed to reduce occupational disease, according to the ASSE press statement.

ASSE members believe that specific issues requiring attention is the comprehensive examination of mineralogical, chemical and physical properties of the asbestos minerals involved in the published epidemiological or medical case studies that will result in the identification of a “risk fiber.” Once this definition of what "fibers" constitutes a "risk" to workers is clarified, there can be new and revised sampling and analytical methods developed that are designed specifically to identify those toxic properties in bulk and air samples which affect human health, according to the press statement.

A major concern to ASSE is that current definitions of asbestos in regulations and analytical protocols count many fibers and minerals that are not toxic while omitting fibers and minerals that are toxic. This is a great concern for those who protect workers’ safety and health, according to the statement.

“This leads to poor risk assessments, poor risk management, poor communication of reality, and poor use of economic and unfortunately, legal resources,” Abrams said. “Although ASSE supports additional research into any potential health effects of these studies, there is no scientific data that would warrant regulating these minerals as asbestos, for occupational health purposes, for public health and consumer protection purposes.”

ASSE notes that a clarification on what minerals are being studied, and precision in distinguishing between those that are properly within the scope of the intended research, is needed before the research begins. However, NIOSH’s position is internally inconsistent, according to the ASSE news statement.

“On one hand, the agency agrees that nonasbestiform mineral analogs of the asbestos minerals are not asbestos, yet it seems intent on counting such minerals as ‘asbestos’ if they meet an arbitrary counting criteria of a method that is not specific for asbestos,” Abrams noted. “In effect, NIOSH’s proposal would include all common antigorite, riebeckite, cummingtonite-grunerite, tremolite, actinolite and anthophyllite as ‘asbestos’ unless their cleavage fragments were less than five microns long or had an aspect ratio that was less than 3:1. This totally disregards what asbestos is in the real world and will minimize, not enhance, protection of health.”

Unless this error is corrected, ASSE notes in its testimony, the NIOSH Roadmap will ultimately skew the results of the proposed research and constitute a waste of public health resources as well as possibly misleading regulators in the future, according to ASSE’s press statement.