The three EC Directives were adopted in 1990-1. They deal with the protection of workers from exposure to asbestos, extend existing curbs on the marketing and use of asbestos, and provide for additional controls on asbestos by classifying it as a category 1 carcinogen.
The EC restrictions on specific types of asbestos will have no implications in the UK because the fibres concerned are either already banned - in the case of amosite - or not used - the three amphibole fibres anthophyllite, tremolite and actinolite - in the UK. Only one small manufacturer of roofing felt will be affected by the EC ban on some further uses of chrysotile.
The Directive on carcinogens will require some modifications to existing UK law on asbestos. In particular, it provides that carcinogens should be replaced "in so far as is technically possible" by a substance, preparation of process which is less dangerous to workers. The HSC has proposed to give effect to this by introducing a statutory duty on employers to prevent exposures to asbestos by replacing it with safer substances or processes "so far as is reasonably practicable." It is by no means clear that this is as stringent a formulation as the EC requirement.
Other novel requirements on UK employers will include a series of issues which must be covered in working plans for the removal of asbestos. A tighter action level is also to be introduced for chrysotile, triggering the need for controls at lower cumulative exposures to the fibre.
The HSC has also proposed amendments to an existing code of practice on asbestos insulation. The revised code will discourage the removal of asbestos by dry stripping methods in the light of studies which have shown that wet removal gives rise to much lower levels of asbestos in air. Other studies have shown that the protection conferred by respiratory protective equipment is sometimes much lower in the workplace than predicted by laboratory tests.
The revised code will also recommend that final inspections of stripping enclosures should be carried out by organisations independent of the removal contractor, and that laboratories used for analysis should conform with European Standards. The change, the HSC says, follows repeated reports of bad practice in clearance inspection and testing at the end of asbestos removal jobs.