Need to Make Andhra Pradesh Free of Cancer Causing Asbestos Fibers

To

Shri S V Prasad,

Chief Secretary/Chairman

Andhra Pradesh Pollution Control Board

Government of Andhra Pradesh

Hyderabad

Subject-Need to Make Andhra Pradesh Free of Cancer Causing Asbestos Fibers



Dear Shri Prasad,

Pursuant to my letter dated May 10, 2007 written to the Chief Minister, Andhra Pradesh, this is to draw your attention towards the proposed Asbestos cement sheet and accessories manufacturing unit of 1,80,000 Tonnes Per Annum capacity at Narsimharaopalem Village, Veerulupadu Tehsil, Krishna District, Andhra Pradesh by M/s Sahyadri Industries Limited.

I am aware that the total land proposed for the proposed project is 50 Acres. The total cost of the project is Rs. 29.7 Crores. The plant is in the proximity of the village Narsimharaopalem and the nearest Railway Station is Rayanapadu. There is a Wira river nearby. The NH 9 is situated at a distance of some 6 Kms. from the proposed site.



In the TOR dated October 25, 2010 issued by Union Environment & Forests Ministry for the proposed asbestos sheet plant there is reference in 45 paragraph refers to “Detailed action plan for compliance of the directions of the Hon’ble Supreme Court of India regarding occupational health and safety measures in asbestos industries should be included”. I submit that in an order dated January 21, 2011, wherein Hon’ble Supreme Court’s bench of Chief Justice of India Justice S.H. Kapadia, Justice K.S. Panicker Radhakrishnan and Justice Swatanter Kumar has observed in para 15, “the Government has already presented the Bill in Rajya Sabha. The statement of objects and reasons of this Bill specifically notices that the white asbestos is highly carcinogenic and it has been so reported by the World Health Organisation. In India, it is imported without any restriction while even its domestic use is not preferred by the exporting countries.” It is noteworthy that once a Bill is introduced in Rajya Sabha, it never lapses.


The Bench of Chief Justice of India notes, “Canada and Russia are the biggest exporters of white asbestos. In 2007, Canada exported 95% of the white asbestos, it mined out of which 43% was shipped to India. In view of these facts, there is an urgent need for a total ban on the import and use of white asbestos and promote the use of alternative materials. The Bill is yet to be passed but it is clearly demonstrated that the Government is required to take effective steps to prevent hazardous impact of use of asbestos.”



I wish to point out that in the TOR there is reference also to “import and transport of Asbestos from Canada”, “chemistry of asbestos, handling of asbestos material”, “Chemical composition of raw material as especially amount of Tremolite, Crocidolite, Amosite and other amphiboles, Hexavalent chromium in raw material especially in serpentine, talc and chrysotile”, “Health Management Plan for Mesothalmia, Lung cancer and Asbestosis related problems in asbestos industries”, “Air quality modelling for the Asbestos handling system” and “monitoring (of) asbestos fibres”.

The reference to anthophylite, tremolite, actinolite amosite and other amphiboles in the TOR reveals that besides chrysotile (white asbestos) and crocidolite (blue asbestos), other forms are also being used in India and is likely to be used in the proposed plant as well.

I wish to inform you that the World Health Organization (WHO) has issued a new factsheet on asbestos:http://www.who.int/mediacentre/factsheets/fs343/en/index.html It re-iterates that the most efficient way to eliminate asbestos-related diseases is to stop the use of all types of asbestos and specifically states that its strategy is particularly targeted at countries still using chrysotile asbestos. The factsheet notes that “more than 107 000 people die each year from asbestos-related lung cancer, mesothelioma and asbestosis resulting from occupational exposure.”

I submit that the Environmental Management Plan mentioned in the Chapter 10 of the DREIA submitted to the Andhra Pradesh Pollution Control Board (APPCB) is an act in fantasy otherwise how does one respond to the work of WHO and International Labour Organization (ILO) towards elimination of asbestos-related diseases “by recognizing that the most efficient way to eliminate asbestos-related diseases is to stop the use of all types of asbestos and by providing information about solutions for replacing asbestos with safer substitutes and developing economic and technological mechanisms to stimulate its replacement.”

I submit that these references in the TOR for the Sahyadri Industries Limited’s proposed asbestos sheet plant must be revised in the light of the above mentioned order of the Hon’ble Supreme Court.

If submissions above create a reason for the public hearing that is scheduled to be held on April 21st, 2011 to be cancelled with immediate effect.

At paragraph 55 of the TOR is mentioned that “Any litigation pending against the project and/or any direction/order passed by any Court of Law against the project, if so, details thereof should also be included”. It is clear that the company in question should be made to submit the above mentioned observations of the Hon’ble Court and the Expert Appraisal Committee-1 (Industry) must re-visited.



I wish to draw your attention towards the struggle of Jana Vignana Vedika and Citizens Forum Against Asbestos to stop the construction of killer plants in Andhra Pradesh. Their struggle is quite legitimate especially in the context of the recent order of the Hon’ble Court. I have learnt that some political activists have warned people of Narsimharaopalem Village, Veerulupadu Tehsil, Krishna District and other environmental and health activists against disapproving the cancer causing asbestos plant at the public hearing.



The DREIA prepared by Pioneer Enviro Laboratories & Consultants Pvt. Ltd., Hyderabad for the proposed project reveals colossal ignorance about how irremediable health impacts have made all the scientific and health institutions of UN call for elimination of future use of asbestos fibers. It fails to acknowledge that in our country mining of all forms of asbestos is banned due to its deleterious impact on health. The Canadian asbestos which is imported reveals the double standards of Canada because on one hand they are decontaminating their asbestos buildings, on other they are promoting it India.



I also wish to express my endorsement of the demands in a letter to Chief Minister dated 30th March, 2011 by National Alliance for People’s Movement (NAPM), Andhra Pradesh urging him to refuse environmental clearance and consent to establish for this plant. A copy of the letter was copied to me.

I wish to inform you that the proposal of asbestos cement sheets factory at Narasimharao Palem, Veerulapalem mandal, Krishna district, Andhra Pradesh would harm the present and future generations of people of Andhra Pradesh in particular. Notably, the Draft Rapid Environment Impact Assessment (DREIA) reveals in Chapter 9 that “Environmental Cost Benefit analysis has not been carried out”. The entire chapter titled “Environmental Cost Benefit Analysis” has only two sentences. It is manifest act of keeping the communities in dark. The fact is that this project will incur huge health and environmental cost and cause incurable diseases like lung cancer. If these costs were made available to the affected communities, the evident hazards would unleash unprecedented outrage among them. The project proponents know it, therefore, they have chosen not to disclose the catastrophic health effect of exposure from asbestos fibers. The DREIA claims that “Complete Medical Records shall be maintained for 15 years after cessation of employment or 40 years from the beginning of the employment whichever is

earlier.” While records must be kept, the question is will keeping these records treat the incurable diseases from which workers who are exposed to asbestos fibers suffer.



I submit that admittedly the affected communities have not been informed about the environmental cost the proposed asbestos sheet plant, therefore, public hearing must be cancelled.



I wish to draw your attention towards the New Delhi Declaration Seeking Elimination of cancer causing all forms of asbestos including Chrysotile from India which was adopted and endorsed by eminent scientists and doctors on 24th March, 2011. This happened at a Round Table which was organized immediately after the conclusion of International Conference on "Emerging Trends in Preventing Occupational Respiratory Diseases and Cancers in Workplace" at Maulana Azad Medical College that expressed grave concern about asbestos related diseases like lung cancer in the national capital. The Declaration is given below for your perusal and immediate consideration.

The delegates at the Round Table discussed the asbestos policy of Andhra Pradesh. They discussed how Andhra Pradesh has become the asbestos capital of the country. They expressed their outrage at Andhra Pradesh government’s policy of promoting asbestos products and their manufacturing units.

These delegates shared their views and gave their valuable hand written notes so that it can be used in a credible way while strongly recommending the need for immediate ban on asbestos to Government of India, State Governments and the relevant ministries.

I wish to submit that during a visit to New Delhi in March 2011, Dr Alec Farquhar, Managing Director, Occupational Health Clinics for Ontario Workers, Canada said, “We now have around 500 asbestos cancer cases every year in Ontario from a population of 13 million. If you (India) continue on your current path, you will multiply our death count by 100 times. That would be 50, 000 Indian workers dying every year from asbestos. In Ontario, we learned that safe use of asbestos is impossible. I urge you from the bottom of my heart, please do not make the same mistake as we made in Canada. Stop using asbestos and use a safe alternative.”

I submit that Professor Elihu D Richter MD MPH, Hebrew University-Hadassah School of Medicine, Israel said, “All form of asbestos kill. India should bury asbestos, not people. Here is a case for examining whether those countries which export asbestos to India are committing a crime against humanity, because they are engaging in willful neglect. India should not repeat the mistakes of going back some 70 years which will kill tens of thousands of workers and their families.” Richter too was in New Delhi in March 2011.

It must be noted that “No matter what mis-information comes of Canada or the Indian asbestos industry about Chrysotile, there is no question that science has shown that Chrysotile causes asbestosis, lung cancer and mesothelioma. This is the conclusion of World Health Organisation. The International Agency for Research on Cancer, and other organizations that have no biases except for protecting people’s health,” said Prof. Arthur L Frank, PhD, Department of Environmental and Occupational Health, Drexel University School of Public Health, US. He was in India to make a presentation at an International Conference on Occupational Health.

I submit that Collegium Ramazzini, a Italy based independent, international academy founded in 1982 by Irving J. Selikoff, Cesare Maltoni and other eminent scientists has called for the elimination asbestos of all kinds. Presenting her views, Prof (Dr) Qamar Rahman, fellow of National Academy of Sciences, Dean, Integral University, Lucknow & former Deputy Director, Industrial Toxicology Research Centre, Lucknow asserted, “This is high time that Government of India should ban the use of asbestos in India. It has been proven scientifically that asbestos based articles such as roof ceilings, storage tanks will release fibers. The asbestos fibers will be the cause of exposure to our coming generations.” This merits your immediate attention.

It may noted that the conference was organised by Centre for Occupational Health, New Delhi supported by Union Ministry of Labour & Employment, ESI, DGMS and DGFASL in collaboration with Drexel University, US at Maulana Azad Medical College, New Delhi from 22-24 March.

The conference was deeply concerned about asbestos related diseases and the alarming rise of asbestos in India.

In such a backdrop, in short, I request you to take steps on the following points:

· Do not grant environmental clearance to the proposed asbestos sheet plant

· Deny Consent to Establish to this hazardous factory unit

· Create a Registry of Incurable Lung Cancers and Mesothelioma besides a registry of asbestos related diseases

· Start efforts to decontaminate asbestos laden buildings including schools and hospitals

· Create a building registry of those buildings and products which have asbestos.

· Include environmental and occupational health study in the medical education of all the medical colleges in the state

· Stop procurement of cancer causing asbestos based products in Andhra Pradesh

· Adequately compensate the victims of asbestos-related diseases, create a database of asbestos exposed people and victims as well besides providing legal and possible medical relief and taking preventive measures

I would be quite happy to share more details about the asbestos related incurable diseases.

Yours Sincerely

Gopal Krishna,

Convener,

Ban Asbestos Network of India (BANI)

National Alliance for Asbestos Free India (NAAFI)

Mb: 09818089660, 07739308480

Email:krishna2777@gmail.com,
Blog:banasbestosindia.blogspot.com

Cc

Chief Minister, Andhra Pradesh

Union Environment Minister

Union Health Minister

Union Commerce Minister

Union Finance Minister

Shri P.V. Ramesh, Principal Secretary, Health, Government of Andhra Pradesh

Member Secretary, Andhra Pradesh Pollution Control Board

Dr P L Ahuja Rai, Director, Union Ministry of Environment & Forests

Collector, Krishna District, Andhra Pradesh

Collector, Vijaywada, Andhra Pradesh


New Delhi Declaration

Seeking Elimination of all forms of Asbestos including Chrysotile from India

Date: 24 March, 2011


Recalling the Ban Asbestos Resolution of 2002, WHO Resolution of 2005 and ILO Resolution of 2006 seeking elimination of future use of asbestos of all forms, in the face of massive asbestos exposure underway in India;

Taking note of The White Asbestos (Ban on Use and Import) Bill, 2009 introduced in Rajya Sabha (Upper House of Indian Parliament) and the order of the Kerala State Human Rights Commission banning the use of asbestos in schools;

Considering the anti asbestos movement against 12 proposed asbestos plants in Bihar in face of massive people’s resistance;

Outraged at the Union of India’s Budget 2011-12’s callous reference to asbestos by including it under the Rashtriya Swasthya Bima Yojana to cover ‘unorganized sector workers in hazardous mining and associated industries like asbestos etc’ and on the other hand Bihar’s Deputy Chief Minister’s Budget is allocating land for 4 new asbestos plants;

Recognising the fact that enviro-occupational health infrastructure in India is weak or non-existent in the face of workers and consumers who are sick and dying from asbestos-caused cancer and other related diseases;

Endorsing The STATEMENT OF OBJECTS AND REASONS of The White Asbestos (Ban on Use and Import) Bill, 2009 introduced in the Indian Parliament that reads: “The white asbestos is highly carcinogenic even the World Health Organisation has reported that it causes cancer. It is a rare fibrous material that is used to make rooftops (roofing material) and break (brake) linings. More than fifty countries have already banned the use and import of white asbestos. Even the countries that export it to India prefer not to use it domestically. But in our country, it is imported without any restriction. Canada and Russia are the biggest exporters of white asbestos. In 2007, Canada exported almost Ninety five percent of the white asbestos it mined and out of it forty-three percent was shipped to India. It is quite surprising that our country is openly importing huge quantity of a product, which causes cancer. This is despite the fact that safer and almost cheap alternatives to asbestos are available in the country. Instead of importing a hazardous material, it will be better if we spend some money in research and development and use environment friendly product. In view of the above, there is an urgent need for a total ban on the import and use of white asbestos and promote the use of alternative material.”

Appreciating Supreme Court of India’s order of 21st January, 2011 that takes cognizance of the above mentioned Bill and the resolutions of ILO and WHO and seeks government to take immediate preventive steps;

Taking cognizance of the human rights violation involved in exposing people to killer asbestos fibers and how even if few asbestos fibre reach the right places, it causes irreversible damage leading to asbestosis, lung cancer or mesothelioma;

Considering Government of India’s role in preventing the listing of chrysotile asbestos as a hazardous product under the Rotterdam Convention, an International Agreement that requires that importing countries be warned of the risks associated with hazardous products is unbecoming of a nation of India’s stature. It is unconscionable that the government knowingly allows trades in a killer product that will cause death of hundreds of thousands of people in India in general and in Andhra Pradesh, Jharkhand, Gujarat, Bihar and Rajasthan in particular and elsewhere in the world;

Reminding the Government of India that there is incontrovertible evidence that creates a compelling logic for making India asbestos free;

Condemning the asbestos exporting countries liaison with the Indian asbestos industry to which Government is turning a blind eye who have unleashed a misinformation campaign about controlled use of asbestos products which is a fantasy;

Disapproving Ministry of Environment & Forests Experts Appraisal Committee on Industry for approving environmental clearance of asbestos plants;

Asserting the fact that so far some 55 countries have banned all forms of asbestos, and are already using alternative materials;

Underlining that almost every international health agency of repute including the World Health Organization, the International Labor Organization, International Agency for Research on Cancer, Occupational Safety and Health Administration, National Institute for Occupational Safety and Health, and the American Cancer Society agree there is no safe level of asbestos exposure. Most recently, the International Agency for Research on Cancer (IARC) reconfirmed that all commercial asbestos fibers - including chrysotile, the most commercially used form of asbestos - cause lung cancer and mesothelioma. In addition, IARC newly confirmed that there is sufficient evidence that asbestos causes ovarian cancer and reconfirmed asbestos causes laryngeal cancer;

We urge the Government to adequately compensate the victims of asbestos-related diseases, create a database of asbestos exposed people and victims as well besides providing legal and possible medical relief and taking preventive measures. We call on the government to create a mesothelioma registry and a building registry of those facilities which have asbestos. We seek inclusion of environmental and occupational health study in the medical education of all the 300 medical colleges in India

We recommend that the Government should start efforts to decontaminate asbestos laden buildings including schools and hospitals

We express shock at the instance countries like Canada using tax-payers money and Canadian embassies to actively promote the sale of asbestos around the world;

We appeal to the Government of India to put a ban on export, import, manufacturing, use and mining of all forms of asbestos including chrysotile (white) in India.

We call upon the Government of India, State Governments in general and Bihar Government in Particular besides Indian Ministry of Health, Ministry of Environment, Ministry of Commerce, Ministry of Labour, Ministry of Consumer Affairs and Ministry of Mines to initiate steps for an immediate ban on use, manufacture and trade of all forms of asbestos (including Chrysotile or White Asbestos).


Endorsed by:

Prof (Dr) Arthur Frank, Professor, Chair: Department of Environmental and Occupational Health, Drexel University School of Public Health, US, Email- alf13@drexel.edu
Dr Aleck Farquhar, Managing Director, Occupational Health Clinics for Ontario Workers, Canada, E-mail- afarquhar@ohcow.on.ca

Professor Elihu D Richter MD MPH, Hebrew University-Hadassah School of Medicine, Israel, E-mail-elihudrichter@gmail.com
Dr Yael Stein, MD, Unit of Occupational and Environmental Medicine, Hebrew University, Israel, E-mail- stein444@gmail.com

Dr Lyle Hargrove, Chairperson, Occupational Clinics for Ontario Workers, Canada, E-mail- lyle.hargrove@gmail.com
Prof (Dr) Qamar Rahman, Fellow, National Academy of Sciences, India & former Deputy Director, Industrial Toxicology Research Centre, Lucknow E-mail- qamar_15@sify.com
Dr. T.K. Joshi, Fellow, Collegium Ramazzini, Italy, E-mail- kantjoshi@gmail.com