The regulation of work on and disposal of Chrysotile (Asbestos Cement) (March 2015)
Left: Fly tipped Chrysotile roofing sheets discarded in a field gateway off the B482 Marlow Road.
Background of Bryan's involvement with Chrysotile
The Partnership owns or rents grain stores and farm buildings at five different farmsteads, many of which have asbestos cement roofs, while some of the Partnership’s workshop buildings are lined with hard encapsulated lining boards containing chrysotile white asbestos.
Bryan’s interest in the disposal of end of life asbestos cement roofing sheets off agricultural barns originated from a paper presented in April 2007 by the Environment Agency’s Principal Officer for Land Quality to the Thames Region REPAC Committee which drew attention to the Hazardous Waste Controls for Agriculture which were about to be introduced in May 2007. Bryan then looked into the science relating to asbestos cement, and convened a Conference to Investigate the Science Relating to Asbestos Cement Products in April 2008 which took place at NFU Agriculture House, Eynsham, Oxford in April 2008. It then became apparent that these new regulations would involve a farmer, when re-roofing a barn roofed with asbestos cement sheets, having to register with the Environment Agency as a ‘Producer of Hazardous Waste’ and having to dispose of the end of life asbestos cement roofing sheets in Hazardous Waste Landfill Sites regulated by the Environment Agency. Research showed that there was no measurable risk to the health of workers handling asbestos cement, and that therefore the new regulations would involve considerable costs and administrative burdens, as well as the unnecessary filling of hazardous waste landfill sites, without any benefit. In a DVD recorded on high definition video on 10th July 2012 and produced by Ian E Sparrowhawk of High Wycombe, Bryan is interviewed by Nikki Vella in the Kensham Farms office on the subject of disposal of end of life asbestos cement. Bryan explains the steps which he took to alert those UK politicians responsible for the interpretation of European Directives on waste disposal to the problems. In particular Bryan describes the significance of the histogram charts from the UK Health & Safety Commission’s Risk Assessment paper HSC/06/55 published in July 2006 entitled ‘A Comparison of the Risks from different materials containing Asbestos’.
Risk Analysis from the Health & Safety Commission paper HSC/06/55 showing annual risk of death per million workers from working with different asbestos containing materials.
Spray and other insulation and Asbestos Insulation Board (AIB) are the two columns in red on the left, asbestos cement is highlighted as causing 0.8 deaths per million workers.
As a sequel to the recorded interview shown above, Bryan Edgley has prepared a “Progress Report on the Requested Revision of Asbestos Regulation in the UK” made up to 4th March 2015 in consultation with Dr John Hoskins FRSC C.Chem the full text of which is shown below:-
Progress Report on the Requested Revision of Asbestos Regulation in the UK made up to 4th March 2015, for Steve Baker MP FRSA by Bryan K Edgley MBE FRSA in consultation with Dr John Hoskins FRSC C.Chem
Asbestos Regulations that result in unnecessary costs to property owners without either protecting the health of workers or saving lives. Preface The word “Asbestos” is a generic term covering different types of naturally occurring fibrous silicates, the main categories being:-
Amphiboles which are iron silicates, insoluble in the acid of the lung. Of these Amosite (“brown” asbestos) and Crocidolite (“blue” asbestos) were mined extensively until the 1970s, at which time the danger to human health following inhalation of the sharp needle like fibres of these amphibole forms of asbestos into the lung was recognised, and its further mining and use in most countries of the world was banned.
Chrysotile (“white” asbestos) which is a magnesium silicate mineral with compressed soft fibres that are soluble in the acid of the human lung. Chrysotile is still mined on a large scale in Russia, China, Brazil and Kazakhstan, and is still used commercially as reinforcement for cement and aggregate to manufacture asbestos cement and similar products used in most countries other than the UK and Europe. In 1999 EU and UK legislation was enacted banning the future sale and use of all products containing white asbestos. This ban did not differentiate between (i) the dangerous amphibole forms of asbestos used prior to the 1970’s for insulation and fire retardant spray applications, and (ii) chrysotile, still widely used in other countries in the manufacture of white asbestos cement without presenting any risk to health. These differences are recognised in the findings of the Health & Safety Commission paper published in July 2006 under reference HSC/06/55 entitled “A Comparison of Risks from Different Materials Containing Asbestos”