OCCUTECH ASBESTOS EXPOSURE

Exposure to asbestos can present a serious health risk if incorrectly protected or not protected during the exposure. Many countries have identified the asbestos risk and implemented measures to reduce this risk. South Africa like a few other countries has banned mining , manufacturing and sale of asbestos and products containing asbestos unless special permission is obtained from the Government. This ban occurred in 2005 and even today some people are selling asbestos products. The ban occurred but the Asbestos Regulations framed under the Occupational Health and Safety Act did not alter to accommodate the change and especially that most work would now involve management of existing asbestos and products containing asbestos and removal or abatement of asbestos or asbestos containing material.

Managing asbestos material was poorly described in the Asbestos Regulations and those involved were provided little guidance. The asbestos removal had some requirements in the Asbestos Regulations but allowed these employees to be exposed to a health risk. The Occupational Exposure Limit in the Asbestos Regulations was 0.2f/cc and this limit is not adequate for employee protection. The American Conference of Governmental Hygienists a world recognised body recommended a limit of 0.1 f/cc in 1994 in their Threshold Limit Value Booklet. Their research and others USA OHSA identified even at this Limit (0.1f/cc) three ( 3) % of those exposed and not adequately protected can suffer from asbestos related diseases . South Africa has an Occupational Exposure Limit of 0.2f/cc implemented in 1994. At this level 6-8% of those exposed could be affected.

In January 2018 the Department of Labour published the Draft Asbestos Abatement Regulations. 
The proposed OEL in this draft is the same OEL as the existing Asbestos Regulations and by now most persons should recognise that at existing OEL (0.2f/cc) a health risk occurs or could occur to those exposed.
The primary purpose of this Occupational health and safety legislation is to protect employees and other person’s health from exposure to a risk in this case an asbestos risk.

If the existing work environment or any other environment has asbestos fibres in the air at the SA current OEL on a daily basis a significant health risk occurs and the existing controls cannot be considered adequate. The current situation is management of existing asbestos or abatement and not working with asbestos. Therefore releases of asbestos fibres at or above the OEL should not be allowed.
No exposure above the existing OEL is acceptable or can be considered to be adequately controlled. Today employees do not work with asbestos and the existing asbestos should not present a daily risk if no work occurs.

Should the asbestos fibre level in air exceed the existing OEL (0.2f/cc) it should be unacceptable and the employer, owner, self-employed person, asbestos contractor should immediately be required to
1)  Document reasons
2) Inform DOL in writing within 24 hours and provide a plan of action and compliance  framework
3)  Appoint an AIA to investigate
4)  If an Asbestos Abatement Project stop work and implement controls to reduce asbestos to acceptable level
Identify the need to implement interim controls and to consider abatement if asbestos fibres in the air cannot be maintained at a safe level (below the OEL).

If this work environment exceeds the OEL of 0.2 f/cc on a daily then employees in this work environment are exposed to a serious health risk. This work area has natural ventilation and employees work in the plant daily. No respiratory protection is used. This and the picture below are common environments where exposure can occur.
 

Above is a photography of asbestos containing material and the damage to the eaves boarding. The eave boarding falls regularly and at times whilst students are at school. The falling sheeting generates airborne asbestos fibres. Asbestos Abatement is planned but the problem is when. The school wants to operate whilst removal occurs.

Asbestos has been banned from mining, manufacturing and sale in South Africa for more than 10 years however the risk still exists in old asbestos mining areas, when asbestos removal occurs and where asbestos material has occurs or is buried and the condition presents a health risk.  Recent court cases in UK have highlighted that more than half of the construction companies do not check or request the site asbestos inventory or register and few have sufficient knowledge on asbestos or asbestos material to identify accurately the risk. South Africa has a similar problem and although we are considering new Regulations on the Abatement of Asbestos this is unlikely to change quickly. Unprotected asbestos exposure can be a long term death sentence. In the UK more than 5000 persons die per year from previous exposure to asbestos. Unlike South Africa the UK Inspectorate and Local Authorities appear to be more active in apprehending violators of the law. Recent court cases have resulted in heavy fines and imprisonment for offenders. The basic issues identified were
-    Use of unqualified persons or companies to perform the assessment.
-    The Assessors had no formal training in occupational hygiene and asbestos
-    Assessors have no recognized previous experience in asbestos investigations or had not worked under a qualified person or accredited Authority.
All persons who are employed to identify, evaluate asbestos, asbestos material or asbestos containing material need to understand that they have a duty of care to those persons who could or would use the information they provide. Occutech has over the years seen many of these reports where the Assessor has missed significant asbestos issues.

A number of years ago Occutech was requested to provide a client an Asbestos free certificate for an oil rig. The oil rig had been inspected and had a certified but the ship owner was advised that the Australian Government would not accept the document unless it had a certified Occupational Hygienist signature. The document in question had a signature of an Asbestos Assessor. Inspection of the oil rig identified potential asbestos in compartment walls (sample analysis confirmed asbestos), clutch pads and disc brake pads for crane and some gaskets to be asbestos. These were all removed by the owner.

Another case was an industrial plant had been assessed for asbestos and had a certificate from an Occupational hygienist that no asbestos was on the manufacturing plant and only asbestos containing material was on some of the buildings roofing .Occutech was requested to do an Environmental Due Diligence for the new owner. The Due diligence identified over 20 tons of asbestos (Crocidolite 100% Blue asbestos) in the metal structure and roofing. The asbestos was used for fire protection and in some areas plaster covered the structure.

Recently Occutech inspected a site where an Environmental Due Diligence identified some asbestos containing material, rated the risk but failed to identify or consider that a greater asbestos hazard was on the site. The asbestos containing material identified were roof sheeting ,wall panels ,guttering and downpipes the risk assessor rating determined this to be high. No explanation of how the risk was determined was provided. Although the asbestos material was not friable and exposure would be limited except if removal occurred. The structure below was risk rated High.

The greater hazard on this site was the site ground level was raised and a previous tenant or owner had disposed of his asbestos waste some of it raw asbestos –Crocidolite and chrysotile under soil or beneath concrete flooring slabs. This Due Diligence missed a significant hazard and potential risk to persons(employees)who unknowingly disturb the buried waste and are now exposed to the risk and also spread the asbestos fibres . The asbestos containing material can be seen in the photography’s below

Asbestos material buried below top of ash and then sand and then asbestos. The photography below shows asbestos buried and opened by a contractor and left. Blue asbestos(Crocidolite) in almost raw form was found in the asbestos buried and is easily seen in the photography below.

 

Legislators and Occupational Hygienists need to embrace their responsibilities and ensure that those who have limited or no knowledge on asbestos and its potential health risk are advised and protected and to demand that only suitably qualified persons are used to determine the risks and the precautions required .

Occutech is an Approved Inspection Authority in Asbestos and is the oldest AIA in South Africa. Occutech has trained occupational hygienists and others in asbestos and performed numerous asbestos abatement and management projects throughout Africa.

A copy of an Asbestos Inventory