If a ban on chrysotile is impose, is it neccessary to consider the health impacts when chrysotile is used under strict control?

If the ban on chrysotile was based on the IARC Monograph, contraceptive pills, alcoholic beverage, wood dust, rubber industry, coal, coke production, underground mining, painting, outdoor air pollution, aluminum products, etc. because they are all in the Group 1 of carcinogens by IARC.

In addition, the IARC Monograph – Volume 100C only answers the simple question: “Can asbestos cause cancer?” rather than consider the carcinogenic risks of each substance (Bernstein et al, 2006), in other words, to what extent of exposure, carcinogens in group 1 will cause cancer, and how the risk is. Indeed, the updated Monograph in 2012 (with counter-argument of Bernstein et al, 2006) of IARC recognized and stated clearly that:

“Carcinogen (cancer hazard) is substances that are capable of causing cancer in some cases, while the risk of carcinogenicity (cancer risk) is an estimate of the carcinogenic effects expected after exposure to carcinogens. This Monograph only assessed whether carcinogens exist or not, although the term “risk” appears in the title of the Monograph published in previous years. It is critical to distinguish cancer hazard and cancer risk, and the Monograph determined whether a substance could cause cancer or not, even if the risks are very low at current exposure levels, because new use with the exposure levels beyond expectation could cause significantly higher risk.”

Therefore, the IARC Monograph – Volume 100C can not be considered as the basis of a request for banning the use of chrysotile as the prohibition of a substance should be based on pathogenic risks in the current condition of production and use. Whereas, many scientific studies showed that in case of single use of chrysotile in controlled conditions, there was no increase in the risks of asbestos-related diseases (see Argument 2); there is no basis to ban this substance, especially when there is no clear research on the safety level of substitutes as many countries (Zimbabwe, Kyrgyzstan) reported in the 7th session of the Rotterdam Convention (2015). Therefore, the ban on chrysotile without proven effects of fiber on human health is unreasonable.

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