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Comments on EPA Asbestos Scoping Document

Posted By Mark Ellis, Monday, September 25, 2017

IMA-NA filed comments last week on EPA’s draft document, Scope of Risk Evaluation for Asbestos.  The scope document will be used in assessing the risks of asbestos under the Toxic Substances Control Act (TSCA).  The document will be central to EPA’s approach in conducting problem formulation, the next step in the process of the required risk evaluation for asbestos.  The IMA-NA comments stress the importance of EPA applying proper mineral science and up-to-date information whenever it addresses the generic term “asbestos.”  Significant and unnecessary confusion is inevitable if it does not.  The comments highlight instances where EPA inappropriately identified non-asbestiform mineral varieties of the six regulated forms of “asbestos” in the scope document as if they, too, were asbestos.  Specific nomenclature and analytical techniques were identified to assist EPA in making the necessary distinctions.

The comments (without the attachments), are attached below.

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Tags:  asbestos  EPA  risk assessment  scope document  TSCA 

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IMA-NA Comments on Asbestos Consultation Document

Posted By Mark Ellis, Friday, June 2, 2017

The Industrial Minerals Association – North American (IMA-NA) filed comments on Canada’s Consultation Document on the proposed regulatory approach to prohibit asbestos and products containing asbestos published on April 20, 2017 (Consultation Document).  The comments note with approval risk management decisions implemented by various governments.  The comments go on to address the scope of the Consultation Document and its approach to the generic and non-mineralogical term “asbestos.”  IMA-NA stressed the importance of applying sound science in a clear fashion to ensure that common rock fragments and soil are not mistakenly included in any regulation ultimately adopted.  To avoid this unintended outcome, the comments highlighted the importance of using Chemical Abstract Service Registry Numbers to identify with specificity the “asbestos” minerals to be covered.  The comments close by expressing support for the proposed general exemption in the regulations of naturally occurring traces of asbestos.

Responses to the Consultation Document will help inform regulations anticipated to be proposed by Environment and Climate Change Canada and Health Canada in December 2017.

The comments, without the attachments, are posted below.


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Tags:  asbestos  Canada  Consultation Document  Environment and Climate Change Canada  Health Canada  nonasbestiform 

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NIOSH Workshop on Elongate Mineral Particles

Posted By Mark Ellis, Monday, May 1, 2017

The National Academies of Sciences Committee on Earth Resources will host a workshop on elongate mineral particles (EMPs) on May 15 and 16 in Washington, DC.  The workshop is sponsored by the National Institute for Occupational Safety and Health (NIOSH) and will address terminology and characterization of elongate mineral particles.  Asbestos fibers are a subset of a larger universe of EMPs, which encompass a broad group of respirable mineral particles of certain aspect ratios. Advancing research and communication about EMP properties and their potential health effects is challenging for a number of reasons including the continued use of inconsistent nomenclature and inadequate characterization of EMPs. One industry concern is the potential for mischaracterizing other EMPs as asbestos fibers, absent comparable mineralogy or asbestos-related health effects.  Participation in the Workshop is either in person or via WebEx.  To register for the Workshop, click here.


Tags:  asbestos  elongate mineral particles  elongated mineral particles  National Academies of Sciences  NIOSH  nonasbestiform 

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Canada Consultation Document on Asbestos

Posted By Mark Ellis, Friday, April 21, 2017

Today the Government of Canada published a Consultation Document regarding its proposed regulatory approach to prohibit asbestos and asbestos-containing products.  The Consultation Document can be accessed through the following link:  http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=A5520893-1.  Comments on the Consultation Document must be received on or before June 4, 2017.  Environment and Climate Change Canada will hold two Webinars on its proposed regulatory approach, one in English on May 10 and one in French on May 11.  A registration form for the Webinars is attached.  IMA-NA filed comments with Environment and Climate Change Canada on its Notice of Intent to Develop Regulations Respecting Asbestos. The comments-in-chief are attached.


 Attached Files:

Tags:  asbestos  Canada  Environment and Climate Change Canada 

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IMA-NA Comments on EPA Risk Evaluation for “Asbestos”

Posted By Mark Ellis, Thursday, March 16, 2017

IMA-NA filed comments with the U.S. EPA to help establish the scope of risk evaluations under development for ten chemical substances designated for priority risk evaluation under the recently reformed Toxic Substances Control Act, specifically relative to “asbestos.”  EPA asked the public for assistance in identifying information related to conditions of use (i.e., intended, known or reasonably foreseen uses) that would assist the Agency in identifying potential exposure scenarios (pathways, routes and populations).  “Asbestos” is a generic term, referring to certain silicate minerals of a particular chemistry and crystalline growth habit, in contrast to certain common silicate minerals with the same chemical formula but a nonasbestiform growth habit.  IMA-NA stressed adherence to good mineral science and urged EPA to focus of its risk evaluations for “asbestos” on the six regulated forms of commercial asbestos.  Evidence that EPA placed in the record to support the scope of its risk evaluations misstated that certain products contained asbestos, when they in fact contained the nonasbestiform analog.

IMA-NA’s comments are posted below.


 Attached Files:

Tags:  asbestos  EPA  nonasbestiform  risk assessment  TSCA 

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Canada Considering Asbestos Regulations

Posted By Mark Ellis, Wednesday, January 18, 2017

IMA-NA filed comments on the Government of Canada's Notice of Intent to Develop Regulations Respecting Asbestos.  The comments respond to the notice of intent published in the Canada Gazette on December 17, 2016.  The next step in the development of these regulations will include consultations with representatives of provincial and territorial governments, industry, non-governmental organizations, the public and other stakeholders.  Input received during these consultations will be considered during the development of the regulations.  These consultations will take place in the spring of 2017, and additional information will be available on the following Web page:  http://www.ec.gc.ca/toxiques-toxics/Default.asp?lang=En&n=A183A275-1.  Interested parties will have another opportunity to make written comments specific to the regulatory proposal during the mandatory consultation period that will follow publication of the proposed regulations in December 2017.

 

The IMA-NA comments, without attachments, are attached.


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Tags:  asbestos  canada  Canadi  environment  health  Regulations 

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Canada Mandates Collection of Information on Asbestos

Posted By Ariel Hill-Davis, Monday, December 19, 2016
The Government of Canada published a notice in the December 17 edition of the Canada Gazette, announcing that it intends to develop a proposed regulation under the Canadian Environmental Protection Act (CEPA) to ban asbestos, including the manufacture, use, sale, offer for sale, import and export. To inform the development of the proposed regulation, the Ministry of Environment and Climate Change has initiated a mandatory Section 71 survey that requires any person who, during any calendar year from 2013-2015, manufactured, imported or exported a total quantity of 5 kg or more of listed asbestos species, whether alone or in concentration greater than 0.1% by weight in a mixture, product or manufactured item, to file a Section 71 survey with the Ministry. The Section 71 survey must be submitted no later than January 18, 2017.

The Canada Gazette notice can be accessed through this link.

Tags:  asbestos  canada  Canadian Environmental Protection Act  CEPA  environment 

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