To
Shri Ajay Tyagi
Joint Secretary
Nodal Point, UN’s Rotterdam Convention on Prior Informed Consent
Procedure for Certain Hazardous
Chemicals and Pesticides in International Trade
Hazardous
Substances Management Division (HSMD)
Union Ministry
of Environment, Forests & Climate Change
New Delhi
Subject: Why India should support inclusion of White Chrysotile
Asbestos in the UN list of hazardous
substances under Rotterdam Convention after Union Health
Minister’s statement to Parliament in 2014[1]
and Prof. Arthur Frank’s affidavit of December 2016 makes NIOH 2012 study
irrelevant
Sir,
With reference
to your invitation seeking
comments and suggestions on matters of the Basel, Rotterdam
and Stockholm Conventions ahead of the the eighth meetings
of the “Rotterdam Convention on the prior informed consent
procedure for certain hazardous chemicals and pesticides in international trade” (RC COP 8), we suggest that a
proposal by African countries to amend
the Convention merits India
support becasue it allows decisions to list hazardous substances
to be taken by a 75% majority vote as a last resort, if consensus proves
impossible, which will
be on the agenda this proposal.
We submit that for
more than a decade the white chrysotile asbestos industry
has refused to allow white chrysotile asbestos to be put
on the Rotterdam Convention’s list of hazardous substances
although it meets all the Convention’s criteria for listing. Thirty-two
scientists from every region of the world, who make up the Convention’s expert
scientific committee, have repeatedly recommended that white chrysotile
asbestos be put on the Convention’s list of hazardous substances.
The right to Prior Informed Consent that the Convention provides has
been rendered null and void by a tiny group who profit from asbestos export and
the Convention is in crisis.
We submit that at
the Seventh Conference of the Parties in 2015
(COP7) a special Inter-Sessional Working Group was set up to resolve the crisis of industry interests preventing
the Convention from being implemented. Some 33 countries
appointed government representatives to be members of this
special Inter-Sessional Working Group. It is noteworthy that amost
all these countries have named one or two representatives but Russia, the top chrysotile asbestos producer
has appointed seven representatives to this special
Inter-Sessional Working Group. The report of
this Group will be discussed at the 8th
Conference of the Parties (COP8) amidst efforts by 15 asbestos
lobby organisations including India’s Asbestos Cement
Products Manufacturers’ Association (ACPMA), a private body
corporate have suceeded in creating
the current crisis in the Convention.
We submit that it appears that influence of the four asbetsos producers of the world who produced 1,799,700 metric tons of
chrysotile asbestos in 2015 (Russia - 1,100,000
tons, Brazil- 310,000 tons, China-210,000
tons and Kazakhstan 179,700 tons) determines whether or not we have the right of Prior Informed
Consent as a right or
not. In a bizzare situation, it is being argued by that this right exists only
if the hazardous white chrysotile asbestos industry
allows it to be exercised.
We submit that to
ensure that it is busness as usual for them they are trying every to keep chrysotile asbestos off the Rotterdam
Convention’s list of hazardous substances through unfair and
questionable means. They have been misleading the media
and asbestos consuming countries by misrepresenting medical and schentific
facts. For instance, in April 2016, Mr
Yerbol Nurkhozhayev, the CEO of Kostanai Minerals, Kazakhstan was asked: “By the way, I cannot but ask you a safety related
question. There is an opinion that the chrysotile is a hazardous substance?” Nurkhozhayev replied: “In
2015, the Parties of Rotterdam Convention arrived at a
conclusion that chrysotile is not dangerous for human health, if safety rules
and standards are observed. Chrysotile was not included into the list of toxic
substances, so the chrysotile industry may further develop both in Kazakhstan
and in the world.”[2]
Kostanai Minerals of Kazakhstan has been
mining the fifth biggest deposit of chrysotile asbestos in the world. It is noteworthy that Russia and Kazakhstan who represent
82% of all asbestos export have been the key
suppliers to India. Its a classic case of fibbing wherein
false claim is made to effect that the Parties to
Rotterdam Convention concluded that chrysotile asbestos is not dangerous for
human health. This is a case of fraudulent misrepresentation of
officially documented facts by the UN’s Rotterdam Convention Secretariat.
With regard to White Chrysotile Asbestos which has been approved by Convention’s Chemical Review Committee (CRC)
for listing in the UN List of hazardous substances, we are enclosing the 216
page long signed and notarized affidavit of Prof. (Dr) Arthur Frank dated
December 20, 2016 for your consideration. His Commission expires July 28, 2018. His
affidavit is consistent with the position of Union Ministry
of Health and Family Welfare, Indian Council of Medical
Research (ICMR) and National Institute of Occupational Research.[3] It
also consistent with position of Union Ministry of Environment, Forests &
Climate Change articulated on Independence Day last year.[4]
Prof. Frank’s affidavit is consistent with the order of National Institute of
Occupational Health (NHRC) as well besides CRC. NHRC passed an order
recommending that the asbestos sheets roofing be replaced with roofing made up
of some other material that would not be harmful.[5] Prof. Frank’s affidavit is one of the most comprehensive and
significant medical and scientific document ever submitted in our country on
this subject given the fact that both workers and consumers are at
fatal risk from the killer asbestos fibers through the life cycle of the
asbestos based products. Prof. Frank is a
renowned expert of impeccable record on the subject and has been a regular
invitee by reputed medical and public health institutions run by govenment in
India for his esteem lectures.
Having learnt that Hazardous Substances Management
Division (HSMD) is the nodal point for the four
International Conventions, we are hopeful that you will be able
to adopt a holistic approach to safeguard the public health of present and
future generation of Indians.
We submit that the
affidavit of Prof. Frank is relevant to the Indian delegation because of what
is stated in the 105 page long Indian Goverment’s Environmental Impact Assessment
Guidance Manual for Asbestos Based Industries.[6]
The relevant part of the Manual reads: “All workplaces where asbestos dust may
cause a hazard is to be clearly indicated as an asbestos dust exposure area
through the use of a well-displayed sign, which identifies the hazard and the
associated health effects” for workers’s education. It also
states, “Pictorial warning signs and precautionary notices for asbestos
and products containing asbestos are to be made” for the
protection of consumers from “hazard and the associated health effects.” During the UN meeting from 24
April to 5 May, 2017, these admitted “hazard and the associated health
effects” with asbestos manufacturing and asbestos containing
products will be the subject of deleberations.
We submit that in a written reply Union Minister of Health and Family
Welfare informed the Parliament on the subject of Asbestos
Related Diseases on February 21, 2014. This reply is most relevant in this regard
in the present context as far as Central Government’s position is concerned.
We submit that the year of the written reply of Union Minister of Health
and Family Welfare is quite significant becasue so far Department
of Chemicals and Petrochemicals, Union Ministry of Chemicals and Fertilizers
have been relying on an outdated, irrelevant, conflict of interest ridden and
questionable ‘Study of Health Hazards / Environmental hazards
resulting from use of Chrysotile variety of Asbestos in the country’, carried
out by National Institute of Occupational
Health (NIOH) [Indian Council of Medical Resarch], Ahmedabad and was co-sponsored
by the Ministry. The study is outdated and irrelevant
because as per a communication from the Department of Chemicals and
Petrochemicals, which is the Designated National Authority for Industrial
Chemicals this study was recieved from NIOH on May 18, 2012.
The reply of the Union Minister of Health and Family Welfare which
proves its irrelevance reads: “The Indian Council of Medical Research
(ICMR) has informed that major health hazards of asbestos include cancer of
lung, mesothelioma of pleura and peritoneum and specific fibrous disease of lung
known as asbestosis. All types of asbestos fibers are responsible for human
mortality and morbidity. Studies have been carried out at National Institute of
Occupational Research, an Institute of ICMR, Ahmedabad which show that workers
when exposed to higher workplace concentration of asbestos fiber have higher
incidence of interstitial lung disease and pulmonary function impairment.
Directorate General Factory Advice Service and Labour Institutes, (DGFASLI)
under Ministry of Labour & Employment has intimated data of workers
suffering from Asbestosis in factories registered under the Factories Act,
1948.As per the information provided by DGFASLI, it is informed that 21 no. of
Asbestosis cases were reported in Gujarat in 2010 and 2 cases in Maharashtra in
the year 2012.”[7]
It noteowrthy that reply is from the
year 2014.
We submit that this clearly indicates that the Ministry of Health
and Family Welfare which is the parent ministry of NIOH, proves
its irrelevance of NIOH’s study of May 2012 because the ministry revisited,
reviewed and revised its position rejecting the findings of the study done by
NIOH in 2012. As a consequence the findings of the latter date as disclosed in
the Parliament prevails. It is evdient that ministry which has jurisdiction
over the subject of health is Ministry of Health
and Family Welfare and not the Department of Chemicals and
Petrochemicals, Union Ministry of Chemicals and Fertilizers, which continues to
parrot the discredited and dubious May 2012 study by NIOH. It is significant to
that the Union Minister of Health and Family Welfare states that “All
types of asbestos fibers are responsible for human mortality and morbidity”, this clearly implies that white chrysotile asbestos is responsible
for human mortality and morbidity.
We submit that a ministry- Ministry of
Chemicals and Fertilizers which remains responsible for continuined industrial
disaster of Bhopal cannot be deemed sensitive enough to protect the public
health of the Indians becasue institutional accountability for the public
health disaster due to acts of ommission and commission of Union Carbide
Corporation/Dow Chemicals Company lies with it. In 33rd year of industrial disaster of Bhopal, it is noteworthy that Dow Chemicals Company
which refuses to own the liability for Bhopal disaster caused by Union Carbide
Corporation (UCC) in India has owned the UCC’s asbestos related liabilities and
announced a compensation fund of 2.2 billion dollars for the victims. In
Europe, tycoons and ministers are facing criminal charges and imprisonment for
their act of knowing subjecting unsuspecting people to killer fibers of
asbestos. The future is no different for Indian culprits. Instead of patronaizing this hazardous industry, the
Ministry of Chemicals & Fertilizers should have compelled the asbestos industry to pay heed to the way asbestos companies
have gone bankrupt in the western countries and should have been made to join hands to create a compensation fund for victims
We submit that
NIOH’s ‘Study of
Health Hazards / Environmental hazards resulting from use of Chrysotile variety
of Asbestos in the country’ dated May 2012 was/is questionable
because “The study has no scientific credibility,” stated Dr. Philip
Landrigan, President of the Collegium Ramazzini and Dean for Global Health,
Icahn School of Medicine, Mount Sinai, New York. “It is flawed in the design,
methodology and interpretation of the results,” he added. The photos
in the study show some workers wearing a cotton scarf tied around their face as
their only “safety equipment”. The study
also shows workers weaving asbestos cloth. This is one of the most hazardous
uses of asbestos. In a Statement calling on the Government
of India, scientists had
urged the government to withdraw this discredited scientific study on
chrysotile (white) asbestos. On an earlier
occasion, the information procured using Right to Information Act revealed that
terms of referance and the inference of a study conducted by NIOH was dictated
by the sponsors of the study.[8]
This has been admitted by two union ministers in the Parliament.
We submit that Union Minister
of State for Environment and Forests informed the Rajya Sabha in a written
reply that the study of the health status of the workers and the residents in
the vicinity of the asbestos industry by NIOH, Ahmedabad was co-sponsored by
the Asbestos Cement Products Manufactures Association (ACPMA). Out of a total
of Rs. 59.66 lacs allocated for the study by Ministry of
Chemicals and Fertilizers, the Asbestos Cement Products Manufactures
Association has contributed Rs. 16 lacs.[9] Union Minister of State for Labour & Employment informed Lok
Sabha gave almost the same written reply about the NIOH study.[10]
It is this very study in major
Asbestos based products manufacturing units located in Kolkata, Silvasa, Vapi
and Hyderabad. which was revised in 2012 folliwng expose of it
being co-sponsored by Asbestos Cement Products Manufacturers Association
(ACPMA).
We can safely state that Union Ministry of Chemicals and Fertilizers was
caught red handed while acting on behalf of the ACPMA when it approached NIOH
to condnduct “A study of health
hazards/environmental hazards resulting from the use of chrysotile asbestos in
the country.”[11]
Following this formal disclosure of this Ministry’s incestous relationship with
the ACPMA in Parliament, it would not be surprising if it continues to work for
ACPMA disregarding public health concerns. This ministry should be asked
explain its questionable condict because it has been institutionaly accountable
for co-sponsoring a doctored study and compromising the position of NIOH. In
the light of the disclosures in Parliament, the coordinators of this study
namely, Dr P K Nag, Dr H N Saiyed and Dr SK Dave owe an explanation to the
sceintific community in particular and unsuspecting citizens in general, we demand
a high level inquiry by a panel scientists into their conduct while
coordinating this questionable study to ascertain as to how such corporate and
commercial interests influenced the findings of their study in order to take
remedial mesaures which can restore the reputation of NIOH and such scientific
institutions.
We submit that the position of Ministry of Chemicals & Fertilizers based May 2012 study by NIOH is inconsistent with the reply of the Union Minister of Health and Family Welfare given in a written reply to the Parliament in 2014 and the latter prevails in matters related to public health. The reply reads: “As per the provisions of the Factories Act, 1948 and rules framed thereunder, manufacture, handling and processing of Asbestos and its products is declared as Hazardous Process. Further, Govt. of India has prepared Schedule XIV- ‘’Handling and Processing of Asbestos, Manufacture of any Article or Substance of Asbestos and any other Process of Manufacture or otherwise in which Asbestos is used in any Form’’ as a Dangerous Operation under section 87 of the Factories Act,1948. The Ministry of Mines has informed that the Grant of fresh mining leases and renewal of existing mining leases for Asbestos are presently banned in the country on Health Grounds.” This was stated by the Union Minister for Health and Family Welfare in a reply to the Lok Sabha.
We submit that this reply is consistent with the observation of World Health
Organisation (WHO) saying,
" All types of asbestos cause lung cancer, mesothelioma, cancer of the
larynx and ovary, and asbestosis (fibrosis of the lungs). Exposure to asbestos
occurs through inhalation of fibres in air in the working environment, ambient
air in the vicinity of point sources such as factories handling asbestos, or
indoor air in housing and buildings containing friable (crumbly) asbestos
materials." It underlines that several thousands of deaths can be
attributed to other asbestos-related diseases, as well as to non-occupational
exposures to asbestos.
As to NIOH
study, while one disagrees with the findings of the conflict of interest ridden
study conducted by the National Institute of Occupational Health, (NIOH), it is
evident that even this study does not state that chrysotile asbestos is not a
hazardous chemical. Had NIOH study
concluded that Chrysotile Asbestos is not a hazardous chemical it may have
become relevant. But even then it would have been legally unsustainable because
under Indian laws chrysotile asbestos is a hazardous chemical.
We submit that if
Ministry of Chemicals & Fertlizers continues to repeat its old position
based on May 2012 study by NIOH, it should be asked why has Union Ministry of
Mines banned the Grant of fresh mining leases and renewal
of existing mining leases for Asbestos (including white
chrysotile asbetsos) in the country “on Health
Grounds”. It is should be asked how is it those admitted “health
grounds” are not relevant for trade in raw white chrysotile asbestos mineral
fibers. This Ministry should be asked to refer to the provisions of the
Factories Act, 1948 and rules framed thereunder, according to
which manufacture, handling and processing of Asbestos and its
products is declared as Hazardous Process. Further, it should
be told that Governmenty of India has prepared Schedule
XIV- ‘’Handling and Processing of Asbestos, Manufacture of any Article or
Substance of Asbestos and any other Process of Manufacture or otherwise in
which Asbestos is used in any Form’’ which admits that it is
a Hazardous and Dangerous Operation under section 87 of
the Factories Act,1948.
In such a backdrop, we submit that at paragraph 407 of
page no. 211, Prof. Frank’s affidavit reads: “I believe that every
occupational, para-occupational, environmental or domestic expsoure contributes
to the risk of developing mesthelioma. From a medical and scientific
perspective, in a person with mesothelioma, it is my opinion that the
cumulative expsoure to asbestos contributes to the total dose of asbestos. The
total cumulative expsoure combines to raise the risk of disease and ultimately,
in someone with disease, to casue a patient’s mesothelioma. Cumulative expsoure
is the scientifically accepted rubric for consideration of exposure levels and
causation of mesothelioma and other asbestos related diseases. All of the
numerous epidemiological studies cited in this affidavit utilize cumulative
expsoure when discussing risk-whether qualitatively or quantitatively. These
are my medical and scientific opinions.”[12] This affidavit is consistent with the reply
of the Union Minister
for Health and Family Welfare which was based on inputs from Indian
Council of Medical Research (ICMR).
At paragraph 408, Prof. Frank writes, “Lung cancer and mesothelioma occur
when asbestos fibers such as those described above cause genetic errors in
epithelial cells lining the airways, or in mesothelial cells that form the
lining of the pleural and peritoneal cavities. All the types of asbestos
fibers, including chrysotile, have shown to cause chromosomal rearrangements
and aneuploid condition that can lead to neoplastic transformation of
epithelial and mesothelial cells. Asbestos damages DNA and causes cancers in
both animal models and humans.”[13]
At paragraph
411, he informs that “Asbestos exposure involves extremely small fibers
released and inhaled in large amounts. But these enormously large amounts look,
on paper, deceptively small.” He further adds, “an unprotected persson may
inhale as many as 80 fibers per minute, 4,800 fibers per hour, 38,400 fibers
per day and 9,600,000 fibers in a 250 day working year.” He underlines that “A
seemingly tiny measured amount of asbestos is
actually a large number of individual asbestos fibers. These fibers are
so small that ‘(y)ou can’t see these fibers in teh air-some asbestos particles
are so small that nearly 200 of them would have to be bundled together to equal
the diameter of one human hair.’[14]
It is quite
significant to note that Prof. Frank has relied upon the methodology espoused
in the Consenus Report, Asbestos, Asbestosis, and Cancer: The Helsinki criteria
for diagnosis and attribution, commonly known as the “Helsinki Criteria”, as
applied to the factual evidence of a patient;s expsoures. The Helsinki Criteria
is well-recognized as a reliable approach to attributing mesothelioma to
specific asbestos exposures, as illustrated by the recent statement on the
issue by 58 Scientists Brief reads: “Internationally respected asbestos disease
specialists reached a scientific and medical consensus, orginally in 1997 and
reaffirmed in 2014, on requirements for experts to attribute a given
mesothelioma to asbestos expsoure. The original 1997 committee consisted of 19
participants of various disciplines from eight (8) countries not producing
asbestos, with over 1000 articles published between them. The resulting
‘Helsinki Consensus’ agreed with the traditional generally accepted approach in
occupational medicine that ‘a history of significant occupational, domestic or
environmental expsoure will suffice for attribution’.”[15]
In his
affidavit Prof. Frank states, “It is my opinion that mesothelioma is a
dose-response disease and that the resulting disease is the cumulative result
of all of the expsoures to asbetsos that a person receives. The cumulative
expsoure that a mesothelioma patient has received in their lifetime has caused
impact to the lungs, has overwhelmed the body’s defence mechanisms, brought about
genetic changes, and has caused mesothelioma or other cancers at whatever site
it develops.” According to him, “This
process takes place as fibers inhaled into the lungs are transported to the
pleura or other tissue and cause injury there, including injury to the
mesothelial cells, regeneration of mesothelial cells, and genetic changes to
mesothelial cells caused by interaction between the asbestos fibers and the
chromosomes of those individual cells. In a person who develops a mesothelioma,
there will eventually be a convers on of one or more of those mesothelial cells
to a malignant phenotype, which then eventually grows into a tumor that
presents clically as a mesothelioma.”[16]
Prof. Frank
finally concludes, “If a person is exposed to fewer fibers, then there iwll be
fewer fibers that ultimately make their way to the pleura. Conversely, if a
person is exposed to more asbestos fibers, there will be more fibers that make
their way to the pleura. This is the nature of the dose-response relationship between
asbestos exposure and mesothelioma: thel more asbestos exposure a person has,
the greater the chance of developing mesothelioma. In a person who develops
mesothelioma, that disease is the result of the cumulative amount of asbestos
and the risk of getting the disease increases with each exposure.”[17]
We submit that in the most recent paper titled, Pleuroperitoneal Mesothelioma: A Rare Entity on 18F-FDG PET/CT published in Indian Journal of Nuclear
Medicine, authored by researchers from Department of Nuclear Medicine, All
India Institute of Medical Sciences (AIIMS), New Delhi and Department of
Radiodiagnosis, AIIMS. This paper authored by Dr Shamim Ahmed Shamim et al
provides credible information about an asbestos related disease of a 40-year-old-female without any history of occupational asbestos
exposure presented with histologically proven malignant pleural mesothelioma.
Malignant mesothelioma is a rare tumor that originates from the cells lining
the mesothelial surfaces, including the pleura, peritoneum, pericardium, and
tunica vaginalis.[18]
We submit that
an earlier 2009 paper titled Pleural mesothelioma: An
unusual case diagnosed on pleural fluid cytology and immunocytochemistry
states, “Mesothelioma is a rare neoplasm with relationship to occupational and
environmental exposure to asbestos. Its accurate and early diagnosis is often
difficult. We present an unusual clinical presentation and diagnostic dilemma
in a 30-year-male, who presented with neck pain and
diffuse edema of left upper limb. The color Doppler ultrasound revealed venous
thrombosis. The right supraclavicular lymph node biopsy revealed a poorly
differentiated carcinoma. The patient had mild bilateral pleural effusion, the
characteristic cytomorphological features of mesothelioma on fluid cytology
were helpful in establishing the diagnosis.”[19]
This paper was co-authored by Dr V K Arora et al from the
Department of Pathology, AlIMS.
It is germane
to inform you that we (ToxicsWatch Alliance) got a reply from Shri R N Jindal,
Union Ministry of Environment & Forests based on Department of Chemicals
and Petrochemicals (DCPC)’s note dated June 18, 2013 on the issue of Government of India’s position on hazardous
substance chrysotile asbestos at the Sixth Conference of Parties of (CoP-6) of the Rotterdam Convention on the Prior Informed Consent
Procedure for Certain Hazardous Chemicals and Pesticides in International Trade
held during April 28-May 10, 2013 in Switzerland. The reply and the note based on NIOH study
are attached because it is apparent that the same note is guiding the position
of the focal ministry even in 2017.
The seven-page
long note of the Department of Chemicals and Petrochemicals (DCPC), Union
Ministry of Chemicals and Fertilizers on the subject of Chrysotile Asbestos
titled ‘Department of Chemicals and Petrochemicals’ View on the use of
Chrysotile Asbestos” in the country’ was shared with ToxicsWatch Alliance (TWA)
by the Union Ministry of Environment & Forests.
We submit that
MoEF’s contention based DCPC’s note stating that “On the basis of the said
note, the listing of Chrysotile Asbestos under Annex ‘A’ of Rotterdam
Convention at CoP-6 during April 28th
-May 10th 2013 at Geneva could not be
supported” was/is misplaced because even this questionable study did not state
that white chrysotile asbestos is non-hazardous.
Having
carefully read the note of the ‘line department’, i.e. Department of Chemicals
and Petrochemicals (DCPC), Union Ministry of Chemicals and Fertilizers on the
subject chrysotile asbestos, we submit that the note of the DCPC reveals that
it has failed to understand the purpose of the Rotterdam Convention and
ignorance about the objective of the Convention.
We submit that
the note is irrelevant from the point of view of the objective of the
Convention for which it was prepared. While one disagrees with the findings of
the conflict of interest ridden study conducted by the NIOH, it is evident from the perusal of this 123 page long study
that it does not state that chrysotile asbestos is not
hazardous. It is also evdient that it did not undertake
cumulative assessment of continued exposure to white chrysotile asbestos. Had
NIOH study concluded that Chrysotile Asbestos is not a hazardous chemical it
may have become relevant. But even then it would have been legally
unsustainable because under Indian laws all asbestos including
white chrysotile asbestos is hazardous.
We strongly
disagree with the concluding sentence of the DCPC’s note saying, “In view of
the above, India may take a stand in the next CoP meeting of Rotterdam
Convention for not inclusion of chrysotile asbestos in Annexure-III of
Convention” because it is irrational and logically inconsistent
and outdated becasue it based on May 2012 study by NIOH. In any case following
the 2014 reply of the Union Health Minister based on inputs from ICMR, it is
manifestly irrelevant.
We reiterate that the flawed conclusion of the note titled
‘Department of Chemicals and Petrochemicals’ View on the use of Chrysotile
Asbestos” in the country’ based on discredited and doctored 2012
study by NIOH is irrelevant and outdated in the aftermath
of Union Health Minister’s reply of 2014 based on inputs from ICMR and NIOH.
We submit that
that there was strong objection at the unethical and immoral act of inclusion
of representatives of Asbestos Cement Products
Manufacturers’ Association (ACPMA), India in the Provisional list of
participants at the Technical workshop on chrysotile asbestos in Geneva,
Switzerland in March 2015. An official on condition of
anonymity that officials feel humiliated when they have to take orders from
likes of ACPMA.
We submit our letter to Union Ministry of Environment & Forests
(MoEF), on behalf of ToxicsWatch Alliance (TWA) was responded and a clarifications were provided, which revealed that the MoEF was misled by Union
Ministry of Chemicals & Fertilizers which in turn was
misled by Asbestos Cement Products Manufacturers’ Association (ACPMA), which
had funded the questionable study by the NIOH.
We submit that
ACPMA had overwhelmed and misled the Indian delegation making the Indian
delegation ignore the fact that Asbestos is listed as a hazardous substance
under Part II of Schedule-I of the Manufacture, Storage and import of Hazardous
Chemical Rules, 1989 under the Environment (Protection)
Act, 1986 provides the List of Hazardous and Toxic
Chemicals. This list has 429 chemicals. Asbestos is at the
serial no. 28 in the list. This Rule and the list is
available on the website of Union Ministry of Environment & Forests.
We submit that
had ACPMA not overwhelmed the Indian delegation, the Indian position would have
been in keeping with its Inventory of Hazardous Chemicals Import in India that
lists ‘asbestos’ at serial no. 26 as one of the 180 hazardous chemicals in international trade which is imported
in India. This inventory was prepared by Central Pollution Control Board (CPCB),
under Union Ministry of Environment & Forests, Govt. of India prepared in
September, 2008 with a foreword September 24,
2008 by Shri J. M. Mauskar, the then Chairman, CPCB and
Additional Secretary, Union Ministry of Environment & Forests This was done
pursue of Government of India’s “Manufacture, Storage, and Import of Hazardous
Chemicals (MSIHC) Rules, 1989” under the Environment
(Protection) Act, 1986. According to these Rules, any
person responsible for importing hazardous chemicals in India is to provide the
data of import to the concerned authorities, as identified in Column 2 of Schedule 5 to the Rules. The CPCB “has
been identified as one of such Authorities. In order to study the inventory of
Hazardous Chemicals being imported by various categories of industrial units in
India, the data provided by these industrial units to the Central Pollution
Control Board (CPCB) have been compiled.” It is scandalous as to why did the
Indian delegation took a position inconsistent with the Manufacture, Storage,
and Import of Hazardous Chemicals (MSIHC) Rules, 1989.
We submit that
even under Factories Act, 1948, the List of 29
industries involving hazardous processes is given under Section 2
(cb), Schedule First, asbestos is mentioned at serial no. 24. The Act defines "hazardous
process" as “any process or activity in relation to an industry specified
in the First Schedule where, unless special care is taken, raw materials used
therein or the intermediate or finished products, bye-products, wastes or
effluents thereof would--(i) cause material impairment to the health of the
persons engaged in or connected therewith, or (ii) result in the pollution of
the general environment”. This leaves no
doubt that asbestos is a hazardous substance.[20]
We submit that
promoters of white chrysotile asbestos like ACPMA who were planted in the
Indian delegation on earlier occasions made the government
representatives take a position against human health and the environment and to
put profit of the asbestos industry before gnawing public health concerns.
We submit that
on June 22, 2011 Indian delegation
led by Ms. Mira Mehrishi, Additional Secretary, had supported the listing of
Chrysotile asbestos as a hazardous chemical substance at the fifth meeting on
Rotterdam Convention amidst standing ovation. TWA had taken the opportunity of
congratulating the government but the about turn on later
occasions under the corrupting influence ACPMA was a sad let down.
We submit that it is reliably
learnt that officials and scientists who go to such UN meetings feel humiliated
when the industry representatives give them directions instead of the senior
government officials or ministers. The UN meet on hazardous chemicals creates a
rationale for insulating government officials from undue and motivated industry
influence else they will be obliged to act like parrots. The Cabinet Committee
on Economic Affairs (CCEA) must factor in the far reaching implications for
public health before defending the indefensible hazardous asbestos industry.
The day is not far when members of CCEA too will be held liable for their acts
of omission and commission as is happening in more than 50
countries that have banned all kinds of asbestos.
In keeping with
Indian laws when the UN’s Chemical Review Committee of Rotterdam Convention
recommended listing of white chrysotile asbestos as hazardous substance it is
incomprehensible as to why Indian delegation opposed its inclusion
in the UN list on earlier occasions. The only explanation
appears to be the fact that the Indian government delegation did not have a
position independent of the asbestos industry’s position which has covered up
and denied the scientific evidence that all asbestos can cause disease and
death.
We submit that
global experience underlines that even early industry-funded studies showed a
causal relationship between asbestos exposure and cancer. Had this been made
known to the public it could have prevented countless deaths but the asbestos
industry made the conscious decision to protect their profits instead and
choose to keep this information hidden from the public. India’s asbestos
industry is following the same path.
As a
consequence, although millions of Indian lives are being lost and millions are
being exposed to the killer fibers of white chrysotile asbestos, no government
agency or company is being held liable due to political patronage which becomes
quite glaringly visible when ACPMA is included as part of the delegation.
We submit that
the very existence of ACPMA is highly problematic and very dubious. ACPMA which
faced charges of cartelization by the Competition Commission of India is
registered under The Societies Registration Act, 1860 and
it claims to be a non-profit organization. Is the asbestos industry a
non-profit organization? They make completely dubious and baseless claims. They
have put profit ahead of public health. These associations appear inhuman,
cruel and have a deviant behavior. The members of ACPMA all await the fate of
Kubota Corporation.
We submit that
in a related development, on April 2, 2013
in a precedent-setting decision, the Israel's Hon’ble High Court of Justice
rejected a petition on against a law placing substantial financial
responsibility on a company to clean up asbestos waste. The order observed, “In
recent years, countries throughout the world have been required to deal with
different dilemmas related to protecting the quality of the environmental. A substantial portion of these dilemmas
involve, among other things, legal, economic and ethical considerations.
Amongst these dilemmas, the removal of hazardous waste – the matter at the
heart of the present appeal – is a subject that demands significant attention. Asbestos, in particular, has proved itself to
be efficient and strong, suitable for many uses. However, it has become clear with time that
its ability to cause damage immeasurably outweighs its potential benefits. Since the 20th century,
different states have dealt with this matter of how to clean up the environment
from asbestos, and onthe questions of who to impose the responsibility and who
to require to pay for the implementation.
Consequently, I have found it appropriate to first turn our perspective
on the relevant legal regimes in a few key countries beyond our borders.” It ruled that "To conclude, the survey
presented (of various international legal perspectives) indicates various and
complimentary components. In all
instances it appears a consensus has been established, certainly so with
regards to materials hazardous by their very nature such as asbestos, that
substantial responsibility is to be imposed on the pollutant."
We
wish to draw your attention towards the verdict of five judges of Japan’s
Supreme Court of February 17, 2015 that has upheld a ruling that found asbestos
used at a plant of Kubota Corporation caused fatal mesothelioma in a man who
lived near the plant and ordered the company to pay ¥31.9 million in damages to
his relatives. The petitioners were relatives of Kojiro Yamauchi, who died at
age 80 after working for two decades about 200 meters from the Kubota plant in
Amagasaki, Hyogo Prefecture. His relatives and those of Ayako Yasui, who died
at age 85 having lived about 1 km from the plant, sought damages from both
Kubota and the government. In October, 2014 this Supreme Court ruled
that the government was responsible for failing to protect workers from
exposure at asbestos factories in Sennan, Osaka Prefecture. It is noteworthy that Japan has banned
asbestos of all kinds including white chrysotile asbestos.
We submit that three cases
of asbestos related diseases i.e. Mesothelioma have been reported
from among the workers of employed in the factory of Hyderabad Industries
Limited, Sanathnagara, Hyderabad in Andhra Pradesh. These workers have died due
to the disease. These workers were: 1) Shri N Chandra Mouli, 2) Shri Sher Khan
and 3) Shri Rama Chandraiah. This was revealed in an affidavit filed by Shri T
Narayana Reddy, Special Officer Office of Advocate-on-record, Andhra Pradesh
Legal Cell, New Delhi in the Hon’ble Supreme Court. This company in question
may be asked to file a report on total number of workers employed by it and
their health status including a report about the three above mentioned workers.
We submit that
National Institute of Occupational Health (NIOH), Ahmedabad, Gujarat
recommended compensation for two workers employed in Gujarat Composites Limited
who were certified to be suffering from asbestosis. This has been revealed in a
reply given by Government of Gujarat. A letter of Chief Inspector of Factories,
Gujarat State dated December 24, 2002
in the matter of execution of the order of Supreme Court in Writ Petition
(Civil) No. 206 of 1986 categorically
reveals that two workers of Gujarat Composites Ltd were confirmed for
Asbestosis, an incurable lung disease by NIOH. The workers were (1)
Shri Hazarilal Manraj and (2) Shri Sahejram B
Yadav. The letter recommended compensation of Rs 1 lakh as
per the Court order but till date the same has not been given. This and many
such cases conclusively establish the hazards from asbestos. Influence of the
asbestos industry becomes quite obvious when Government turns a blind eye to
such glaring official facts. This is
also a clear case of contempt of court by the asbestos based company. It may be
noted that Gujarat Composite Ltd (formerly named Digvijay Cement Company)
appears to be attempting to hide behind myriad corporate veils by changing
names and by outsourcing its work. The official letter
demonstrates that white chrysotile asbestos is a hazardous substance which
causes asbestos related incurable diseases.
We submit that Secretary,
Medical Education & Research, Chandigarh Administration which has
categorically informed National Human Rights Commission (NHRC) that “a. White
Asbestos (Chrysotile Asbestos) is implicated in so many studies with the
following diseases:-Mesothelioma (Cancer of Pleura), Lung Cancer, Peritoneal
Cancer, Asbestosis, And also consider as cause of following cancers:- Ovarian
Cancer, Laryngeal Cancer, Other Cancer b. Diseases are produced in the person
involved in Asbestos Industry.” It states that “No. of
cancer deaths due to asbestos requires further large scale study from India”.
It informs, “It is definitely harmful material, causing cancer and other
related diseases.”
It quotes from
Pulmonary Medicine journal saying, “Asbestos is a set of six naturally
occurring silicate minerals exploited commercially for their desirable physical
properties. However, it has been proved beyond doubt that Asbestos is hazardous
to humans. White asbestos has been found to have causal relationship with
various diseases like pulmonary asbestosis, lung cancer and mesothelioma
leading to deaths of thousands of people every year.”
The reply of Chandigarh
Administration concludes saying, “Hence, use of white asbestos should be
completely banned in India also and the same may be replaced by some safe
alternative material.” Chandigarh Administration has realized the public health
consequences of exposure to fibers of asbestos.
We submit that Assistant
Labour Commissioner, Union Territory, Chandigarh has referred to para 16 of the judgment of Hon’ble Supreme Court dated January 21, 2011 passed in Writ Petition (Civil)
No.260 of 2004 wherein directions of
January 27, 1995 in the Writ Petition
(Civil) No. 206 of 1986 is required
to be strictly adhered to. It further
states, “In terms of the above judgement of this Court as well as reasons
stated in this judgement, we hereby direct the Union of India and States to
review safeguards in relation to primary as well as secondary exposure to
asbestos keeping in mind the information supplied by the respective States in
furtherance to the earlier judgement as well as fresh resolution passed by the
ILO. Upon such review, further directions, consistent with law, shall be issued
within a period of six months from the date of passing of this order.” As to ‘fresh resolution passed by the ILO’,
it is noteworthy that “A Resolution concerning asbestos was adopted by the International
Labour Conference at its 95th Session in 2006.
Noting that all forms of asbestos, including chrysotile, are classified
as human carcinogens by the International Agency for Research on Cancer (IARC),
and expressing its concern that workers continue to face serious risks from
asbestos exposure, particularly in asbestos removal, demolition, building
maintenance, ship breaking and waste handling activities, it calls for: – the
elimination of the future use of asbestos and the identification and proper
management of asbestos currently in place as the most effective means to
protect workers from asbestos exposure and to prevent future asbestos-related
diseases and deaths.”
We submit that
in a letter dated May 29, 2012, Joint
Secretary, Government of Uttarakhand has referred to a
document Medline Plus Trusted Health Information for You, U.S. National Library
of Medicine and the prescription of National Institutes of Health (NIH)
highlighting the Treatment stating: “There is no cure. Stopping exposure to
asbestos is essential.”
We
submit that Indian Navy officials have rightly objected to presence of asbestos
in aircraft carrier Admiral Gorshkov which was inducted into the Indian Navy as
INS Vikramaditya after asbestos decontamination. It is not surprising that Union Ministry of Labour’s concept
paper declares, "The Government of India is considering the ban on use of
chrysotile asbestos in India to protect the workers and the general population
against primary and secondary exposure to Chrysotile form of Asbestos. The
Concept paper of the Central Government notes, "Asbestosis is yet another
occupational disease of the Lungs which is on an increase under similar
circumstances warranting concerted efforts of all stake holders to evolve strategies
to curb this menace".[21]
It has been
estimated that one person dies from mesothelioma for every 170
tons of asbestos consumed. WHO estimates we have107,000
deaths worldwide per year from occupational exposure to asbestos. If non
occupational exposure is added it reaches a figure of about 120,000
deaths. Average world consumption/year 30-60 years ago was
-- looks like3/2 of what it is now (2
million metric tons/year). Give India its share of that based on its share of
global consumption. At 300,000 tons in 2013,
that's about 18,000 deaths (15% of 120,000). Asbestos
diseases have a very long incubation period. So if you are exposed today to an
asbestos fibre, you are likely to get the disease in next 10-35
years. Asbestos is like a time bomb to the lungs and Indians will suffer the
most. If it is banned today that does not mean people will not suffer. Because
of past usage people will continue to suffer from these diseases.
It is clear that lack of documentation and lack of environmental and occupational
health infrastructure does not mean lack of victims of asbestos related
diseases.
We submit that
Indian laws include asbestos in the list of hazardous substances but in past the Indian delegation has been misled by
the asbestos industry lobby groups like Asbestos Cement Products Manufacturers
Association which exercises undue influence to advance its
parochial, myopic naked lust for profit at any human cost.
As a consequence of their ill influence Indian delegation has been persuaded to
take a position which is diametrically
opposite of domestic laws.
We submit that the upcoming UN meet on hazardous chemicals creates a rationale
for insulating government officials from undue and motivated industry influence
to ensure that they are not made to act like parrots. In matters like exposure
from carcinogenic fibers of asbestos CPCB officials must factor in far reaching
implications for public health before defending the indefensible hazardous
asbestos industry. The day is not far when officials who are
members of the Indian delegation too will be held liable for their acts
of omission and commission as is happening in more than 50 countries that have
banned all kinds of asbestos.
We submit that
Hazardous Substances Management Division of Government of India
should be wary of people from Asbestos Cement Products Manufacturers’
Association (ACPMA). The representtaives of
this corporate association has been undermining India’s stature among the
global scientific community for long.
It may be noted
that he Competition Commission of India (CCI) had observed that “The
market of asbestos cement sheets consists of 20 big firms and 68 manufacturing
units, of which top six players hold 87 per cent of the market share.” Indian delegation should not allow itself to
become hostage of profit-driven ACPMA, which as per its website
“is a non-profit organization and is registered with the
Registrar of Societies under Indian Societies Act 1860. The Association was
formed in 1985 with an objective to aid, stimulate and advise promotion of
Chrysotile Asbestos Cement Products (Sheets and Pipes) in India. ACPMA is
affiliated to International Chrysotile Association, (ICA), USA. ICA is an
international body formed by various country Associations and has a membership
of 23 countries prominent being Canada, Brazil, China, Russia, Mexico amongst
others. ICA actively represents the interest of Chrysotile Industry world
over…”
We submit that The ACPMA website admits, “ACPMA regularly receives from ICA latest
information on various technical, scientific and health related issues
connected with the safe use of Chrysotile. All such information is disseminated
amongst Members and others connected with the Industry including Govt.
regulatory bodies.” Its website refers to a URL saying,
“To view the list of members alongwith their office address”. The URL shows 18
members instead of 15. These are A Infrastructure Ltd, Assam Roofing Ltd,
Everest Industries Ltd, Hyderabad Ind. Ltd, Jaiprakash Associates Ltd, Sahyadri
Industries Ltd, Ramco Industries Ltd, Tamil Nadu Cements
Corpn. Ltd, U P Asbestos Ltd, UAL Industries Ltd, ‘Konark
Mani Uday’, Visaka Industries Ltd, Sturdy Industries Ltd, Vilson Roofing
Products Pvt. Ltd, North East Roofing Ltd, ARL
Infratech Ltd, Sri Venkateswara Pipes Ltd, Roofit Industries Ltd and
MRK Pipes Ltd. The question which
merits attention is how is it that these profit making companies when they
become members of the Asbestos Cement Products Manufacturers Association
(ACPMA) turn into “a non-profit organization and is registered with the
Registrar of Societies under Indian Societies Act 1860”. Essentially, its claim
of being a non-profit NGO is factually incorrect in essence.
ACPMA undertakes the exercise of defending the profit
making enterprises of these hazardous asbestos based companies
throughs act of fraudulent misrepresentation. Indian delegation should be wary of them.
We submit that the crucial question is can the Indian delegation resist the
influence of foreign interests working through ACPMA to ensure that public
health interest triumphs over immoral, unethical and myopic commercial
considerations of foreign asbestos producers to defend India’s supreme
interest. The manufacturers in India can easily shift to non-asbestos materials
for manufacturing and some of them have started to move in that direction in
South India.
We submit that
early industry-funded studies showed a causal relationship between asbestos
exposure and cancer. Had this been made known to the public it could have
prevented countless deaths but the asbestos industry made the conscious
decision to protect their profits instead and choose to keep this information
hidden from the public. India’s asbestos industry is following the same path.
We submit that Indian delegation should take an independent position without being bullied
by countries like Russia, Kazakhstan, Kyrgyzstan, Ukraine, Zimbabwe and
Vietnam and support the listing of White Chrysotile
Asbestos as a hazardous chemical becasue CPCB’s
inventory and other Indian laws mention it as a hazardous chemical.
We
submit that it is eminently consistent with the principle of Prior
Informed
Consent
for India which imports White Chrysotile Asbestos from countries like Russia,
Brazil, Zimbabwe, Kazakhstan and others to receive the information to assess
whether it has the ability to safely use this substance or products containing
it. The fact remains that the Convention is about prior informed consent about
trade in hazardous chemicals and not about banning any hazardous substance.
We
submit that India should not allow itself to be misled by asbestos producers
like Russia and Kazakhstan in this regard now that Canada has rightly stopped
mining of white chrysotile asbestos almost like India due its “deleterious”
impact on health.
We understand that
given the fact that the decision with regard to India’s position at the UN
meeting is dictated by Department of Chemicals and
Petrochemicals, Union Ministry of Chemicals and Fertlizers, we urge you to ensure that the error ridden position articulated
with regard to white white chrysotile asbestos at the UN
meet in Geneva in past is revisited,
reviewed and revised to set matters right.
We submit that as per Environmental Impact Assessment
Guidance Manual for Asbestos Based Industries[22], the Terms of Reference (TOR) that is
awarded by the Experts Appraisal Committee (EAC), Industrial Project, Union
Ministry of Environment & Forests for Chrysotile asbestos based roofing
factory asks the project proponent to prepare a “Health Management Plan for
Mesothelmia, Lung cancer and Asbestosis related problems in asbestos
industries” revealing its hazardous nature. Instead of relying
on the wisdom of competent ministries of environment, health and labour, Department of
Chemicals and Petrochemicals, Union Ministry of Chemicals and Fertlizers
chooses to rely on the questioanble wisdom of ACPMA and seem to reside in their
make believe world because of not so inexplicable reasons.
We submit that the
recommendation to list white chrysotile asbestos to the PIC list can be a remedy for the mistake committed in the past to pave the way for making India free of incurable
hazardous asbestos related diseases. While we remain quite alarmed to note that Cabinet Committee on Economic
Affairs, Government of India does not include Ministers of Consumer Affairs,
Health, Labour, and Environment, we hope that despite such
a structural constraint myopic commercial considerations will not triumph over
gnawing concerns related to consumers, public health, workers, and environment.
We demand that vested interests like
ACPMA and conflict of interest ridden
experts should
not be included in the Indian delegation and it must support its inclusion in
the Annexure III of the UN’s
Rotterdam
Convention in Geneva.
We keep our fingers crossed in this conflict between Truth Versus Profit
till 5 May, 2017 when the UN meeting concludes. In the light of the disclosures in
Parliament, we propose to set up an independent inquiry committee to examine
the relationship of officials with the ACPMA and asbestos producing countries
after CoP 8.
We submit that
the affidavit, the manual, the doemstic laws, minister’s replies,
papers and their recommendations
indicates significant health/environment hazards resulting from the use of all kinds of asbestos including white chrysotile
asbestos. These papers are relevant to the
recommendation by the UN's Chemical Review Committee for listing in Annex III,
wherein the COP has to take a final decision on inclusion of white chrysotile
asbestos in Annex III at the COP meeting of Rotterdam Convention.
We submit that
the following countries have taken cognizance of the hazardous nature of all
kinds of asbestos including white chrysotile asbestos: 1) Algeria, 2) Argentina, 3) Australia, 4)
Austria, 5) Bahrain, 6) Belgium,
7) Brunei, 8) Bulgaria, 9) Chile, 10)
Croatia, 11) Cyprus, 12) Czech
Republic, 13) Denmark, 14) Egypt, 15) Estonia, 16) Finland, 17)
France, 18) Gabon,
19) Greece, 20) Germany, 21) Gibraltar, 22) Hungary, 23)
Honduras, 24) Iceland, 25) Iraq,
26) Ireland, 27) Israel, 28) Italy, 29) Japan, 30) Jordan,
31) Kuwait, 32) Latvia, 33) Luxembourg, 34) Lithuania, 35) Mauritius, 36) Mozambique, 37) Malta, 38) Netherlands, 39)
New Caledonia, 40) New Zealand, 41) Norway,
42) Oman, 43) Portugal, 44) Poland, 45) Qatar, 46) Romania,
47) Saudi Arabia, 48) Sweden, 49) Switzerland, 50) Serbia, 51) Seychelles, 52)
Slovakia, 53) Slovenia, 54) South
Africa, 55) South Korea, 56) Spain, 57) Turkey, 58) Uruguay and 59)
United Kingdom. We can learn from them in this regard.
In view of the above, we urge you to
take cognisance of the findings of Union Health
Minister in 2014 and concern
of the Union Environment Minister expressed in 2016 besides
studies by AIIMS,
UN,
WHO and the affidavit by Prof. Frank in order to initiate action at CoP 8 of Rotterdam Convention which provides an opportunity to demonstrate that our
Government does not put blind profit above public health and it is concerned
about the public health of present and future generations.
Therefore, we urge you to ensure that India supports the proposed
amendment from the twelve African countries represents the only hope of ensuring that the white chrysotile asbestos industry and other hazardous industries do not get the right to cause the demise of the
Convention.
Warm Regards
Dr Gopal Krishna
ToxicsWatch Alliance (TWA)
Mb: 08227816731, 09818089660
E-mail-1715krishna@gmail.com
Web: www.asbestosfreeindia.org, toxicswatch.org
Dr Gopal Krishna
ToxicsWatch Alliance (TWA)
Mb: 08227816731, 09818089660
E-mail-1715krishna@gmail.com
Web: www.asbestosfreeindia.org, toxicswatch.org
We
may admire what he does, but we despise what he is."-referring to humans
who act mechanically on instructions
-------Wilhelm
von Humboldt, 1792
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[18] (2017), Shamim Ahmed
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[20] (1948), Factories Act, http://labour.nic.in/upload/uploadfiles/files/ActsandRules/Service_and_Employment/The%20Factories%20Act,%201948.pdf
[21] (2011), Concept Paper, presented by Union
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