VNRA Official Dispatch No.05 – Report and recommendation on the use of chrysotile in Vietnam

Dispatch No 05/BC-HHTLVN sent by the Vietnam National Roofsheet Association to all agencies and departments of Ministries, the National Assembly and the Government regarding “Report and recommendation on the use of chrysotile in Vietnam”.

VIETNAM NATIONAL ROOFSHEET ASSOCIATION

_______________________

 No: 05/BC-HHTLVN

Re: Report and recommendation on the use of chrysotile in Vietnam

SOCIALIST REPUBLIC OF VIETNAM

Independence – Freedom – Happiness

_____________________

 Hanoi, 14 March 2019

Respectfully to:

  • Comrade Nguyen Phu Trong – the General Secretary of the Party Central Committee, President of the Socialist Republic of Vietnam;
  • Comrade Nguyen Xuan Phuc – Politburo member, Prime Minister of the Socialist Republic of Vietnam;
  • Comrade Nguyen Thi Kim Ngan – Politburo member; Chairwoman of the National Assembly;
  • Comrade Tran Thanh Man – Secretary of the Party Central Committee, Chairman of the Central Committee of the Vietnam Fatherland Front;

And:

  • Comrade Tong Thi Phong, Politburo member, Standing Deputy Chairman of the National Assembly of the Socialist Republic of Vietnam;
  • Comrade Truong Hoa Binh, Politburo member, Deputy Prime Minister of the Socialist Republic of Vietnam;
  • Comrade Vuong Dinh Hue, Pulitburo member, the Socialist Republic of Vietnam;
  • Comrade Pham Binh Minh, Politburo member, Deputy Prime Minister and Minister of Foreign Affairs;
  • Comrade Truong Thi Mai, Member of the Politburo, Secretary of the Party Central Committee, Head of the Central Committee for Mass Mobilization;
  • Comrade Vu Duc Dam, Member of the Party Central Committee, Deputy Prime Minister of the Socialist Republic of Vietnam;
  • Comrade Trinh Dinh Dung, Member of the Party Central Committee, Deputy Prime Minister of the Socialist Republic of Vietnam;
  • Standing Committee Secretary;
  • Central Propaganda Committee;
  • Central Economic Committee;
  • Standing Committee of the National Assembly;
  • Ministry of Planning & Investment;
  • Ministry of Justice;
  • Ministry of Construction;
  • Ministry of Industry and Trade;
  • Ministry of Health;
  • Ministry of Science and Technology;
  • Ministry of Natural Resources and Environment;
  • Ministry of Foreign Affairs;
  • Ministry of Labor, Invalids and Social Affairs;
  • Ministry of Information and Communications;
  • Government inspector;
  • Government Committee for Ethnic Minority Affairs;
  • National Assembly Committee on Science, Technology and Environment;
  • National Assembly Committee on Social Affairs;
  • National Assembly Committee for Ethnic Minority Affairs;
  • Vietnam Fatherland Front;
  • Vietnam General Confederation of Labour;
  • Vietnam Women’s Union;
  • Nam Vietnam Chamber of Commerce and Industry;
  • Chairmen of 63 Provinces/Cities;
  • Head of National Assembly Delegation 63 Provinces/Cities;
  • Vietnam Union of Science and Technology Associations;
  • Vietnam Federation of Civil Engineering Association;
  • Vietnam Association for Building Materials.

Founded in 2000, Vietnam National Roofsheet Association (VNRA) is a professional association representing 37 establishments and 5,000 employees of asbestos-cement (AC) roof sheet production industry. The VNRA protects the right of businesses and acts as a bridge between businesses and Government agencies at different levels; at the same time, encourages businesses to strictly comply with regulations of the Government on conditional business line, supports businesses to improve product quality, provides training, and organizes seminars to collect and provide information on issues affecting the industry to all members.

AC roof sheets have been manufactured in Vietnam since 1963. After nearly 60 years, this roof sheet has proven its usefulness due to its affordable price and high durability; it satisfies the demand of low-income people and live-stock farming sector because it is not oxidized in the harsh climate of coastal and high mountain areas.

However, over the last 20 years, AC roof sheet production industry has gradually declined. Unstable policy together with proposals to ban the use of chrysotile has severely impacted the operation of businesses. All companies have been struggling to maintain operation; some factories have shut down while other have to look for other business due to the effect of negative information promoted by anti-chrysotile groups on the health impact of chrysotile which is an adhesive material accounting for only 10% of the total input materials of AC roof sheet production.

Since 2,000 years ago, asbestos has been known as a naturally occurring mineral which can be found in almost two-thirds of the earth’s crust. Natural air, soil and water contains a certain amount of asbestos. With superior characteristics such as durability, heat and fire resistance, asbestos fiber is widely used in the industries of producing cement products, insulating materials, automobile industry, aviation, pharmaceutical sector, oil and nuclear industries, production of fireproof materials, textile products, etc. In the past, improper use of asbestos fibers such as spraying along with poor working conditions was the cause of lung diseases for workers. The patients with pneumonia discovered today are the consequences of amphibole exposure from 20 to 40 years ago.

Studies have clearly demonstrated that amphibole asbestos is straight and needle-like and has a long half-life; once in the human lung, amphibole fibre could cause tumors and inflammation symptoms. After 10 to 20 years of incubation, the tumor will develop into cancer and other lung related diseases. Whereas chrysotile is curly and soft, when entering human body via inhalation, chrysotile will be disposed from the lung in 0.3 to 11 days or decomposed by the acid environment created by the macrophage.

Vietnam along with many other countries in the world such as Russia, Kazakhstan, China, India, Thailand, the Philippines, Singapore, Sri Lanka, Laos, Cambodia, has only used chrysotile fibers.

90% of chrysotile is used as an input material in asbestos cement product in which chrysotile accounts for 8-10% of composition, other materials include cement and natural coal ash with 55% and 35% respectively. Accordingly, chrysotile fibers are firmly adhered to cement particles throughout the production process, together with wet and closed technologies, the fibers are difficult to disperse into the environment. Therefore, the risks on public health and the environment have also been reduced.

I. The root of anti-chrysotile campaign

1.1 The global campaign to ban chrysotile asbestos

The anti-chrysotile movement is taking place in many countries around the world by a network of advocacy organizations to create impact on local governments. Founded in 2000, International Ban Asbestos Secretariat (IBAS), led by Laurie Kazan-Allen, has continuously impacted national and international organizations to put pressure on member countries. It is not a coincidence that her brother, Steven Kazan, is a veteran lawyer on asbestos related litigation. Kazan law firm has more than 40 years of experience on asbestos litagation with millions dollars earned from plaintiff fee each year. Because of this “super-profitable business”, asbestos-related keywords become the most expensive keywords in the US when law firms are willing to pay huge expenses to advertise their services. In addition to law firms, a group of countries is also active in the fight against chrysotile, especially Japan, Korea and Australia with APHEDA as one of the most active anti-chrysotile organizations in Vietnam. It is not a surprise that these countries are leading suppliers of PVA fibers and corrugated iron sheets, materials promoted by anti-chrysotile organizations as alternative options to AC roof sheets.

1.2 Anti-chrysotile campaign in Vietnam

In Vietnam, campaign to advocate for the ban on chrysotile has been active since 2000. Over the last 18 years, thousands of articles and TV broadcasts have reported on the so-called health impact of chrysotile, hundreds of seminars and conferences to call for a ban on import and use of chrysotile have been organized by Ministry of Health initially. For the last five years, NGOs have taken charged for those activities.

Although no cases of mesothelioma associated with chrysotile exposure have been identified, from 2015 to 2017, the Ministry of Health had proposed “the Action Plan to eliminate asbestos-related diseases” to “reduce new diagnosed cases of asbestos-related diseases by ceasing the use of chrysotile by 2020; enhancing public health, protecting the environment, and promoting social and economic development”.

Despite stating that the harmful effects of chrysotile on human health has not been agreed, considering human health as a long term issue, the Ministry of Construction has submitted the Official Dispatch No. 1170/ BXD-VLXD 24 May 2017 to the Office of the Government which mentioned recommendations of members of Vietnam Chemical Society to cease the use chrysotile. Therefore, the Ministry of Construction has proposed to develop a roadmap and solutions to support enterprises that are producing chrysotile in production to stop the use of chrysotile by 2023.

2.Anti-chrysotile organizations in Vietnam

2.1 Vietnam Ban Asbestos Network (also known as VNBan)

VNBan is a non-official organization aiming to advocate the Government of Vietnam to prohibit the use of chrysotile. VNBan is a branch of ABAN – Asian Ban Asbestos Network – and IBAS – International Ban Asbestos Network.

The original members of VNBan consist of:

  • Vietnam Occupational Safety and Health Association;
  • Vietnam Chemical Society;
  • Vietnam Standards and Consumers Association (VINASTAS);
  • Evidence-based Health Policy Development (EBHPD);
  • Non-Government Organization – Information Center (NGO-IC).

However, the Vietnam Standards and Consumer Protection Association has remained quiet and no longer been a member of VNBan after the incidence referred as a “faulty analogy” by media. In 2016, VINASTAS published a study showing that traditional fish sauce contained arsenic which caused public panic and consumers initially boycott the product. However, it was later revealed that the information was misled and distorted leading to a crisis at this organization.

Evidences have showed that most activities carried out by the VNBan are supported by the WHO, ILO, and APHEDA in terms of finance, techniques and experts.

Accordingly, the VNBan has developed a strategic plan with numerous activities, especially seminars and conferences to promote the ban on chrystile in Vietnam. Professors, doctors, and experts harshly state their bias, subjective opinions despite the fact that none of them have seen chrysotile in person, visited Asbest – a 125-year-old city located nearby a chrysotile mine, or talked a worker in AC roof sheet production industry. Meanwhile, the VNRA and roof sheet factories, who are directly involved and affected, are often not invited to attend those seminars and conferences because the VNRA and factories would have different opinions and require participants to see the issue from scientific perspective; whereas, no evidence on health impact of chrysotile in Vietnam has been detected.

A wide-spread communication campaign called “Community says No to asbestos” funded by APHEDA has been implemented across different media channels from central to local with the support from Confederation of Labour in Nghe An province. The program replaces AC roof sheets by steel roof sheets at selected households to spread the fear in community. The communication materials distributed at local community houses does not differentiate chrysotile and amphibole, which has severely affected the businesses.

2.2 The reason for extreme advocacy for the ban on chrysotile by VNBan

For public health?

While not a single case of cancer caused by chrysotile has been reported, other factors contributing for thousands of deaths each year are not advocated to ban by these organizations.

According to a statistics of the WHO, 60,000 deaths in Vietnam[1]  were linked to air pollution and 79,000 people died from alcohol consumption in 2016[2].. Particularly for lung cancer, the International Research Agency for Cancer (IARC) has recorded 20,710 deaths in Vietnam by 2018[3]. The main causes of cancer reported by the WHO include smoking, alcohol consumption, obesity, lack of physical exercise and improper fuel use. If VNBan members applied the same enthusiasm and resources to advocate in these fields instead of a natural fiber which has not caused any death in Vietnam, the number of deaths of cancer in Vietnam could decrease significantly.

As for construction material industry, the Health Environmental Management Agency – Ministry of Health has recorded that by 2015, the number of people diagnosed with pneumoconiosis was 20,993 cases, accounting for 74.2%, of which the majority was silicosis[4]. Silicosis is a lung condition caused by inhalation of silica particles occurring in the stone mining, cement production, bricks and fine stone production, coal mining, metallurgy.

Banning chrysotile for long-term human health benefit is one of the most common reason used by VNBan members. While these organizations advocate for the ban on chrysotile without proven health effects in Vietnam; other toxic agents which are scientifically proven to pose a risk to human health such as air pollution, tobacco, pesticides, preservatives, or in the construction materials industry such as coal and cement mining are not the subject of these organizations.

Ban due to the “recommendation of the WHO”

An over-repetitive argument used by VNBAN members is the recommendation of WHO on stopping the use of chrysotile because all types of asbestos are carcinogens. They often state that “there are many international studies on this issue that it is unnecessary for Vietnam to conduct one. Vietnam should follow the recommendation of international organizations”. Blindly trust an organization because of their inherent prestige while rejecting another group based on personal prejudice against that industry does not help the Government approach the truth. Without conducting scientific research studies, how members of VNBan can obtain their PhD and Professor title? It is unable to educate the medical students that “the world has studied the disease already; you do not need to study about it anymore”.

Not only on chrysotile issue, any recommendation of an international organization on environmental, health, public administration or human rights issues requires the Government of Vietnam to have comprehensive assessments in terms of legal, scientific and practical bases to manage in accordance with the national situation and conditions.

In May 2017, the World Health Assembly (WHA) instructed to consider and apply “differentiated approach towards various forms of asbestos in line with the relevant international legal instruments and the latest evidence for effective interventions”.[5] Similar to the case of 18,000 bottles of Chinsu chili sauce produced by Masan Group were withdrawn in Japan market due to benzoic acid containing. If Vietnam also banned the substance following Japan, perhaps this product should be immediately recalled in the domestic market.[6]

Anti-chrysotile activists always mention that chrysotile is classified by the International Agency for Cancer Research (IARC) as a Group I in the list of carcinogens for human. However, they fail to mention that Group I also contains many factors such as processed meat, coffee, sunshine, and late night work.[7] Processed meat is in Group 1 because it is thought to be related to colorectal cancer. With 133,000 cases of colorectal cancer diagnosed in the US in 2018, should humans stop eating processed meat [8].

Ban due to the advantages of steel roof sheet and PVA roof sheet?

In addition to health reason, anti-chrysotile groups present that steel roofing and PVA roofing have many advantages over fibro cement sheets that AC roof sheets should be replaced to these sheets. Even the advocacy groups have affirmed that Vietnam had two successful PVA roof sheet production factories which have exported abroad. However, the reality shows that these two types of products neither meet the requirements of consumers nor is suitable for the economic conditions of many Vietnamese households.

Two enterprises included in pilot projects of Japan to invest in the production roof sheet using PVA fiber were Navifico and Tan Thuan Cuong JSC. Navifico has been closed for 2 years; the General Director of the factory Nguyen Cong Ly has claimed quality defects and high prices of PVA roof sheet as the reason for the failure at the 2017 annual meeting of the VNRA. Mr. Nguyen Cong Ly confirmed that the factory has shut down for a while at the Conference co-hosted by two Committees of National Assembly.

Finding themselves unreasonable, the VNBAN argued that the failure of PVA production lines were due to unfavorable policies. Perhaps they did not visit Vinh Chau village in Soc Trang, where 12,000 PVA roof sheets produced by were funded by the World Bank in 2004. Last year, the residents had to remove the majority of PVA roof sheets because the roof sheet could not withstand the coastal climate. Or they themselves did not visit Tan Thuan Cuong factory to know that their PVA roof sheet shipment to Korea has been broken, and the company could that handle the issue thus switched to AC roof sheet production.

In terms of health, chrysotile fibers have been used for hundreds of years while PVA fibers have been put into use for more than 10 years, thus has not been proven safe for human health. On the other hand, PVC, another type of roof sheet material, is believed to cause diabetes and obesity.[9]

In the case of steel roof sheet, the VNRA has conducted a fieldtrip to mountainous provinces from 13 February 2017 to 11 January 2018 on the use of roofing materials in coastal and mountainous provinces in Vietnam. Actual results and feedback of people have showed that lower price steel roof sheets have a life span from 3 to 7 years. With severe weather condition and high salinity levels in the air, steel roofing is quickly rusted and warped. In particular, households using steel roofing for livestock purpose commented that steel roof sheets are quickly oxidized due to pig manure just after 2 years. Due to the people in Central Vietnam, Mekong Delta and mountainous areas not choosing steel roofing anymore, steel roofing producers have to restructure their market.

The VNRA has repeatedly questioned the reasons for the “enthusiasm” of the VNBan to promote the replacement of AC roof sheets by two types of roofing sheets when they are not suitable to the consumer needs and weather conditions of Vietnam. Without receiving financial support from PVA fiber group and steel roof sheet producers, where does VNBan get budget from?

2.3 VNBAN’s strategy to advocate for the ban on chrysotile in Vietnam

Instead of using scientific evidence to argue about public health issues, the experts and professors of VNBan try to mislead, talk about unrelated issue, personal attack, take advantage of audience’s empathy.

Misleading

As an effective way to advocate, the VNBan misleads audience by using seemingly scientific reasonable argument while in fact it is distorted and unscientific proven.

At their seminars and conferences, the VNBan members argue that “the world has studied on this use, why does Vietnam need to study anymore?”, “Vietnamese is no difference from others, if they can have asbestos-related diseases, Vietnamese can too”. But they have not mentioned that many of those studies were conducted from 20-50 years ago, when amphibole and chrysotile asbestos were used together by spraying and without strict regulations as current ones. They also ignore that there are many other countries with hundreds of years of using chrysotile such as Russia, China, India … where families with several generations have worked in chrysotile mines or chrysotile product manufacturing.

While the studies implemented by the Ministry of Health, Ministry of Natural Resources and Environment, and Ministry of Construction for the last 20 years have not reported any cases of cancer caused by chrysotile, VNBan members have blamed it on “the inconsistence in cancer data record system on employees exposed to chrysotile” and “the incapacity of domestic researchers to diagnose asbestos-related diseases”.

A Ministry-level study named “Research on asbestos-related diseases on exposed people” had been conducted from 2009 to 2011 by the Health Environment Management Agency – Ministry of Health with support from Ministry of Health, Labour and Welfare of Japan through the WHO. The results of this study is often omitted although it has demonstrated that among 447 cases of asbestos-related diseases diagnosed in Vietnam, 37 samples were sent to Hospital of Hiroshima, Japan for further diagnosis; only 08 cases were mesothelioma and none of them showed association to occupational chrysotile exposure. In some platforms and seminars, the “experts” choose to speak “half of the truth” by saying that hundreds of cases of mesothelioma while leave out the fact that “asbestos is not the only cause of mesothelioma” and “no association between these cases and chrysotile exposure was detected”.

Although chrysotile has been a controversial issue for the last 20 years, no data system has been developed by the Government, when will it be? In fact, the Hospital of Construction has developed their own data software to keep track on the health of workers at AC roof sheet factories, but it is probably disregarded by the VNBan. If a research study conducted by the Ministry of Health with the support from a developed country as Japan is not recognized, which research will be? If countries such as Australia and Japan have a lot of experience in diagnosis and compensation for mesothelioma patients, why do all proposed programs to eliminate asbestos-related diseases only focus on policy advocacy communication without studying the health impact?

Only scientific evidences can argue scientific evidences. We can only criticize research methods and results of a study by a study showing otherwise. Using subjective opinion to disregard other competence and study results is not scientific.

Personal attack

When scientific evidences do not support their arguments, the documents and communication materials switch to attack any individual who supports the safe and controlled use of chrysotile.

Using social media platform such as Facebook, professors, PhDs of VNBan do not hold back on their extreme criticism to put pressure on anyone who has different opinion.  The people whom they call “comrades” in official documents become “the “speakers” for the asbestos benefit group under the mask of parliamentary delegates[10], “killers without guns“, ” the asbestos interest groups have instigated the Prime Minister to continue using chrysotile” or “the Government is currently being manipulated by interest groups. ”

The factories which are operating according to the law, paying taxes and creating jobs for workers, are called “inhuman enterprises“. The VNRA wonders if organizations and people, who are willing to deny scientific evidence, legal and practical bases for the use of chrysotile over almost 60 years causing struggles to enterprises and job losses to workers, can be called as “human”?

Even people like Dr. David Bernstein[11], Dr. Robert P. Nolan[12] – two scientific researchers with two studies on the effects of chrysotile fibers on human health are also considered to be in the interest group and their research works are labeled as unreliable regardless of whether these studies are published in peer-reviewed scientific journals. The International Research Agency for Cancer (IARC) itself has recognized the research of these two scientists as prestigious and used them as references for the IARC Cancer Monograph.

Take advantage of audience’s sympathy

The experts and doctors of VNBAN have aggressively promoted the sympathetic model to gain the support of audience despite that mentioned cases neither exist or are associated to chrysotile. They invited two war veterans, who lived in Khu Cho Sang, Luc Dau Giang, Pha Lai ward, Chi Linh, Hai Duong province where has recorded unusual high number of cancer cases in the past several years, to cry at a seminar and claim that the cause of cancer is the AC roof sheet factory in the region. Due to this information, a participant stated “30/100 people have died while others are in incubation process, we need to help the remains. What if your spouse or child die? Compensation is needed“. They completely ignored that besides the fibro-cement roofing factory operating from 1994 to 2011 (now closed) there is a thermal power plant built in 1975. According to Ms. Nguyen Hoang Phuong (Pan Nature) at the seminar on 23 December 2014, there are 6 sources of pollution in Hai Duong. After the workshop, a series of newspapers reported that the cancer village was caused by a roof sheet factory using chrysotile.

A member of VNBan even affirmed that “One or two cancer villages should be mentioned for warning regardless of the real cause of cancer. As long as there is an AC roof sheet factory in the area, just put the blame on it”.

Dr. Nguyen Quoc Quang, when talking about the effects of chrysotile on human health, has shared a story of a family member diagnosed with cancer. This person is undergoing cancer treatment at the hospital and has to spend hundreds of millions every month. However, he does not mention which type of cancer this person is diagnosed with.

Although AC roof sheet producers have been putting efforts to fulfill their social responsibility by donating for the poor, victims of natural disasters, or collaborating with Dan Tri newspaper to build schools for children in remote areas, their kind action is denied by the VNBan saying that “the poor have to use AC roof sheets, once being suffered from cancer, they do not have money for cancer treatment”.

Meanwhile, the VNBan has neither joined any scientific research on chrysotile nor helped the poor. They have only replaced AC roof sheets by steel ones for which they wore fully protective equipment to record and photograph which spread fear in community. Their action does not bring any benefit for enterprises and workers. Fabricating cancer cases to put the blame on chrysotile is antiscientific.

III. The legal basic for the use of chrysotile as a conditional business line

3.1. The legal basic for the use of chrysotile as a conditional business

Chrysotile is regulated as a conditional business line at documents: Law on Chemicals (Provision 1, Article 8 Degree No. 113/2017/ND-CP); Law No. 3/2016/QH13 Amended Law Article 6 and Appendix 4 on the list of conditional business line under the Law on Investment; Law on Technology Transfer (Decree No.  76/2018/ND-CP dated 15/5/2018); Provision 1, Article 7, Law on Enterprises No. 68/2014/QH13; Article 32, Decree 24a/2016/ND-CP on management of construction materials; Clause 12, Article 2, Decree 81/2017/ ND-CP; Clause 8, Article 2, Decree No. 98/2017/ND-CP;

3.2. Directive documents of the Prime Minister: No.7232/VPCP-KGVX dated 11/07/2017 on assessing the use of chrysotile in roofing production, proposing a roadmap to stop using chrysotile and find substitute materials which the requirements and affordability of the people; Document No.7772/VPCP-KGVX dated 16 August 2018 and Document No.8604/VPCP-KGVX dated on 8 September 2018;

3.3. The opinion of the Ministry of Justice in the document responding to the draft roadmap of the Ministry of Construction: According to the Law on Organization of the Government in 2015, the roadmap to ban the use of chrysotile in AC roof sheet production is not under the authority of the Prime Minister.

3.4. Thus, the proposal “Roadmap to stop the use of chrysotile to stop the production of AC roof sheet by 2023” proposed by the Ministry of Construction and the proposal to ban the use of chrysotile in Vietnam in 2020 in the “National Action Plan to eliminate asbestos-related diseases by 2020 with the vision toward 2030” of the Ministry of Health is contrary to the current provisions of Vietnamese regulations which allow the conditional use of chrysotile, not in accordance with the Law on Organization of the Government in 2015 and inconsistent with the functions and duties stipulated by the Government for two ministries. These proposals have caused tremendous damage to businesses and workers in the production of asbestos-cement roof sheets.

IV. The scientific basis for the use of chrysotile as a conditional business line

4.1. The studies on the impact of chrysotile in the world

  • The results of studies conducted by experts from Germany, Austria, Australia, the U.S, and Canada have not detected free chrysotile dust in community using AC roof sheets.
  • A great deal of international studies has shown that the rate of respiratory diseases, health and mortality rate of people exposed to chrysotile through work or use is not different from non chrysotile exposed individuals:
  • The study by Weill, H., Hughes, J. and Waggenspack, C. (1979) – American Review of Respiratory Disease 120(2):345-354.
  • A study on the mortality rate of workers exposed to chrysotile in Greece in 39 years conducted by L. Sichletidis D., Chloros D., Spyratos A.-B., Haidich I., Fourkiotou M., Kakoura D. and Patakas (2008).
  • The studies implemented by Thomas published in 1982, the United Kingdom.
  • The study by Gardner, M.J., Winter, P.D., Pannett, B. and Powell, C.A. (1986).
  • The research conducted by Dr. Jacques Dunnigan (Canada) (2014) on “The epidemiological and toxicological studies of chrysotile fibers and exposure risks”. The results have demonstrated that chrysotile is safer than amphibole, especially under controlled use, its health impact on workers and users is minimized.
  • Similarly, the studies on the concentration of chrysotile in the air at community with popular use of AC roof sheets in Australia, Germany, and Austria have indicted that the concentration of chrysotile is not different from the concentration of chrysotile in natural environment being 0.001 fiber/cc which is considered as “acceptable”, “insignificant” by the WHO, Ontario Royal Commission on Asbestos, and London Royal Society.
  • The study by Dr. David Bernstein (Switzerland) (2013) on “Health risks of chrysotile” clarified the difference between chrysotile and amphibole. Chrysotile has cylindrical structure composed of smaller bundles of fibrils and can be easily degraded in acid environment in the lung (von Kobell, 1834; Pundsk et al, 1988); The external surface of the crystal structures of the amphiboles is quartz-like, and has the chemical resistance of quartz. Therefore, amphibole fibers have negligible solubility at any pH that might be encountered (Speil and Leineweber, 1969).

Dr. Bernstein recommended to acknowledge the difference between two types of mineral fibers when implementing worker health protection measures. Today, only chrysotile is used mainly in mixing with cement to create high adhesion. The risk of cancer when exposed to amphibole asbestos is very high; the use of amphibole in the past caused consequences today.

Therefore, without differentiation between chrysotile and amphibole on the health impact, it is impossible to eliminate asbestos-related diseases effectively.

4.2. Domestic studies on the health impact of chrysotile

Currently, no research has found evidence of diseases due to chrysotile exposure in Vietnam while thousands of industrial chemicals and toxic pesticides are still in use. Many industries in Vietnam such as stone, coal, mineral mining cause more than 22,000 cases of silicosis, while only 3 cases of mild asbestosis were reported.

In 2002 – 2003, Health Center of Construction, which is now known as Hospital of Construction, conducted a “Study on asbestosis and occupational cancer at AC roof sheet production facilities” which is a part of a State-level project “Research and evaluate occupational environment at AC roof sheet production facilities and health impact of chrysotile – Recommendation for solutions” conducted by the University of Civil Engineering. The project was implemented in 10 AC roof sheet production facilities in Northern, Central and Southern Vietnam with modern, semi-modernized and manual labour production process. It also included 14 retired workers with over 30 years of experience. The results showed only 4 cases of asbestosis in total 1,032 workers, which accounted for 0.39% of examined workers and 0.08% of total workers in the industry; this number was very small comparing to to rate of silicosis (6.7%) and other occupational diseases. No lesion of asbestos related diseases such as pleural plaque, pleural thickening and calcification was detected. No cases of malignant diseases such as bronchial lung cancer and mesothelioma have been detected among the workers examined. Moreover, retrospective records of mesothelioma cases diagnosed at K Hospital – Hanoi and Pham Ngoc Thach Cancer Hospital – Ho Chi Minh City from 1991 to 2001 did not show enough evidence to conclude if any case was associated with AC roof sheet manufacturing in Vietnam.

During a 10-year-period (2008 – 2018), the Hospital of Construction – Ministry of Construction has implemented annual occupational health examination program and environment measurement for AC roof sheet manufacturers complying with the guideline provided by the Ministry of Health on occupational health examination and environment measurement. The results of consultation over the last 10 years published by a prestigious council have not reported any cases of asbestosis.

From 2014 to 2016, the Hospital of Construction had implemented a Ministry-level project “Study the health impact of chrysotile on workers at asbestos cement manufacturing factories and users of AC roof sheets”. The study was conducted on 2,459 workers at 32 AC roof sheet production facilities and 100 retired workers with over 30 years exposed to chrysotile. The results did not detect any asbestosis lesion or malignant lesion of lung cancer and mesothelioma. No case of pleural plaque was found. No chrysotile fiber was reported in measuring air samples at 30 locations in Tan Trinh commune – Ha Giang province, where 70% of household were using AC roof sheets,

Regarding users of AC roof sheet, the study has investigated health status and mortality rate of residents in Tan Trinh commune, Quang Binh district, Ha Giang province. Initial research results on cancer situation and mortality rate in Tan Trinh commune showed that the crude mortality rate in Quang Binh and Ha Giang is at average level compared to other regions in Vietnam and in the world. Causes of death in the community did not show any abnormalities; the annual cancer mortality rate of the whole district ranges from 0.63 ‰ – 1.26 ‰; the mortality rate in Tan Trinh commune was lower than the average of the district, the rate of death caused by cancer in Tan Trinh ranked 5th among 15 commune in Quang Binh district (0.858 ‰).

From 2010 to 2011, the Health Environment Management Agency – Ministry of Health had implemented a Ministry-level study called “research on asbestos-related diseases on exposed people”. 447 cases of asbestos related diseases such as asbestosis, lung cancer, pleural thickening, pleural plaque, pleural calcification were diagnosed at 06 hospitals consisting of K Central Hospital, Ho Chi Minh City Oncology Hospital, Central Lung Hospital, Cho Ray Hospital, Pham Ngoc Thach Hospital, and 103 Hospital – Military Medical Academy. The results indicated that the association between occupational exposure to chrysotile and studied objects was insignificant and unclear. Specifically, among 46 (10.29%) out of 447 cases was diagnosed with mesothelioma, 06 showed association with chrysotile such as living AC roofed houses and living near serpentine mine; whereas, no case was exposed to chrysotile occupationally. 34/401 cases of other asbestos-related diseases were associated with chrysotile, accounting for 8.48%, of which 3.74% had worked in chrysotile related occupations and 4.74% had lived in AC roofed houses. 39 specimens of diagnosed mesothelioma were sent to Japan for further examination, 08 cases were identified as mesothelioma, accounting for 20.51% and none of them had a history of exposure to asbestos.

The national profile on asbestos related diseases set up by the National Institute of Labour Protection was an assignment in the project “Occupational Health Protection” led by the Health Environment Management Agency – Ministry of Health from 2009 to 2011. This project was funded by Japanese Government through the WHO. In 2009, the National Institute of Labour Protection began developing the National Profile based on the guideline of WHO/ILO with 19 categories including: legal documents related to asbestos, asbestos imports and asbestos-containing products, asbestos mining, manufacturing industries using asbestos, occupational environment, total number of workers (asbestos workers) exposed to asbestos, asbestos related diseases and research works.

In 2010, the National Profile was updated with the information on workers in ship building and repairing, thermal and insulation industry. Also in 2010, it was added with the profile of workers with age, number of years on the chrysotile product manufacturing and serpentine mining industry as well as the capacity of local healthcare centers on occupational environment measurement and occupational health examination. It was concluded that among the X-ray and CT scanner films for workers exposed to asbestos from 2004 to 2012, no asbestos-related diseases had been detected.

4.3 Therefore, the basis to protect human health by proposing a roadmap to ban the use of chrysotile by 2020 of the Ministry of Health is not reasonable due to the lack of convincing evidence; in 55 years of the asbestos cement roofing industry in Vietnam, no cases of mesothelioma associated with chrysotile have been detected. While many substances, products, chemicals and hazardous industries are not banned, is it a matter of human health? The Ministry of Construction and Ministry of Health need to present evidences and comparison between the rate of diseases and death caused by chrysotile in AC roof sheet manufacturing and that of other industries such as tobacco, peptide, preserve substances, weight-gain substances used in livestock farming, alcoholic beverage, mining, metallurgy, chemicals, transportation, construction to have an objective overview of the situation.

V. Practical basis for the conditional use of chrysotile

5.1 The use of chrysotile in the world

Currently, there are 139 countries and territories including countries in G7, G20 such as the U.S, Canada, Russia, India, China and ASEAN countries which have not banned the use of chrysotile.

In 1991 the US Supreme Court revoked the ban on chrysotile due to the lack of convincing evidence and substitute materials. Currently in the United States allows the use of chrysotile-containing products including: flat and corrugated AC sheets, textile products, tape, tiles, pipes, friction materials, brake pads, etc.

In Russia, chrysotile is mined and manufactured in multiple industries. There are 16 factories producing asbestos cement products with total productivity of 300 million square meters of flat and corrugated sheets fulfilling 52% of demand for roofing material in Russia and 12,000km asbestos cement pipes for water supply, irrigation, gas supply and waste disposal.

Asbest city with the population of 80,000 people was built over 80 years ago located nearby Uralasbest mine. The city is designed with modern Russia style with wide street, 3-5 story houses roofed by AC roof sheets, water supply and irrigation using AC pipes. The mortality rate and life expectancy does not show any abnormality comparing to the national rate.

Yasniy is a 56-year-old town in Orenburg province with the total population of 20,000 people of which 4,500 are employees at Orenburg Minerals and other chrysotile related businesses. The town was founded for chrysotile mining industry and military camp and rocket storage. As a young town, Yasniy has the highest birth rate in Orenburg province while the mortality rate is only a half of that of Orenburg province; the number of retirees only accounts for 15% of the population. According to the head doctor of Yasniy Hospital, within 56 years, no employees or residents have been diagnosed with cancer caused by chrysotile although the mine is located only 10 km away from residential area. The town has buildings and houses which are made mostly of materials from asbestos cement such as roofs, ceiling panels, inner cladding, exterior cladding, water supply pipes.

India is one of the largest consumers of chrysotile in the world with total import of 460 thousand tons annually.

China consumes 550,000 tons of chrysotile annually, of which two-third is mined domestically while the rest is imported.

Brazil is the world leading producer and consumer of chrysotile with the volume of 300,000 tons mined at the largest mine in 2012, of which 54% is for domestic use while the rest is exported. There are 3,000 chrysotile containing products which are mainly asbestos cement, friction, materials, textile, chemical and interior furniture. More than 60% of national population are using water from chrysotile containing pipes and tanks. Brazil currently has 20 factories producing AC products with a total annual output of 168 million m2 of AC roof sheets.

Germany is currently using 50,000km asbestos cement pipes for water supply. Technical documents have confirmed that the quality of water supplied by AC pipes meets German standards for water, which demonstrates that living in AC roofed houses and drinking water from AC pipes is safe.

5.2. The practical basis for the use of chrysotile in Vietnam

In Vietnam, AC roof sheet is a highly demanded by farmers and people living in remote, mountainous and coastal area with low-income. Especially, it is effective in post-disaster recovery to build temporary houses and warehouse for livestock and agricultural products due to its affordable price easy transportation. Products of asbestos cement roof sheets are affordable but durable, light, good quality, insulated, sound-proof, heat-proof, and suitable for coastal climate with high salinity. AC roof sheet industry has made an effective contribution to the poverty reduction and disaster recovery programs of the Government.

Currently, there are 40 factories with 50 productions line manufacturing AC roof sheets with the design capacity of 105 million m2/year. The total production is from 60 to 80 million/years while the consumption ranges from 50 to 80 million m2/year. In addition to the production of asbestos-cement sheets, some other industries also use chrysotile in production such as brake pads, gaskets, heat-resistant seals, insulation materials, heat-resistant products for thermal power, shipbuilding, and fire fight clothes.

AC roof sheet production industry has operated in Vietnam for 55 years but no evidences of deaths and diseases caused by chrysotile have been reported. This should be considered and compared with other industries when developing policy in this issue.

5.3. The situation of non-chrysotile roof sheet production in Vietnam

The results of the State-level project KC-06 “Research, design, and test non-asbestos roofing production lines with capacity of 500,000 m2 /year” was applied at Viet-Nhat roof sheet factory in Nghe An. However, the factory has shut down this line and replaced by AC roof sheet production and subsequently closed operation in 2016.

The State-level project KC.03.DA 03/11-15 “Improve the technology of non-chrysotile corrugated and flat sheet with capacity of 3 million m2/year” was applied for Tan Thuan Cuong JSC – Ha Duong province and later for Navifico JSC – Ho Chi Minh city. In fact, Tan Thuan Cuong JSC has switched to produce AC roof sheet since 2008, the company only has only produced 5% of non-chrysotile sheet for pre-order customers. Similarly, Navifico started operating in 2014 but only produced 5% of designed capacity and closed the business in 2017.

These lessons should be taken into account when reviewing, evaluating and promoting research results in producing products for social demand.

At present, no substitute fiber to chrysotile has been found to produce non-asbestos roofing sheets effectively. The research results using PVA fiber as an alternative fiver to chrysotile have shown that the characteristics of PVA fiber is poor leading to more complicated production technology with large investment while the quality and durability is lower than AC roof sheet and especially worsen in hot and humid climate. Moreover, the price of PVA roof sheet is 50-80% higher than that of AC roof sheet, which is not accepted by consumers.

VI. Recommendation

With mentioned content, the VNRA would like to propose to leaders of the Party, Government, National Assembly, leaders of committees, ministries, government departments, committees of the National Assembly and local leaders as follows:

6.1. It is crucial to distinguish the differences between chrysotile fiber and fibers in amphibole group (brown and blue asbestos) in terms of structure, properties and toxicity. The operation of AC roof sheet manufacturing for over 55 years to supply billions square-meters of AC roof sheet for houses, barns, and warehouse across the country, including the memorable house of Former General Secretariat of the Party Do Muoi can be seen as an evidence. It is crucial to consult the scientific and practical bases for the reasons why 139 countries and territories with more than 6 billion people, including G7 and G20 countries such as the US, Russia, China, India and other Southeast Asia countries have not banned chrysotile? The reason why several countries, which once prohibited the use of chrysotile, have provoked the ban should be taken into consideration.

6.2. Recommendations for the instruction of the Prime Minister

a) When constructing schemes, programs and policies regarding the use of chrysotile in AC roof sheet production, the ministries and departments should understand and comply with legal regulations on the use of chrysotile as a conditional business line, as well as respecting for the rights of enterprises using chrysotile in AC roof sheet production.

b) The Ministry of Construction reviews thoroughly the opinion of the Ministry of Justice in the document commenting on the roadmap of the Ministry of Construction to comply with the Law on Organization of the Government in 2005 and other provisions of law; carefully review the instructions of the Prime Minister in the documents: No. 7232/ VPCP-KGVX dated 11 July 2017 on assessing the use of chrysotile in roof sheet production, propose a roadmap to stop the use of chrysotile in line with researching alternative materials meeting consumers’ requirements and affordability; and instructions in Official Dispatch No. 7772 / VPCP-KGVX on August 16, 2018; Official Dispatch No. 8604/ VPCP-KGVX dated 08/9/2018; Official Dispatch No. 509/ VPCP-KGVX dated 17/01/2019 and recommendations in Report No. 1149 / BC-UBKHCNMT14 to:

  • Stop implementing the project “Roadmap to stop the use of chrysotile in AC roof sheet production by 2023”;
  • Resolve completely the recommendations of Vietnam National Roofsheet Association and enterprises producing asbestos-cement roof sheets, continuing to allow the production and use of asbestos-cement roof sheets according to legal regulations on the conditional use of chrysotile.

c) The Ministry of Health does not attach the ban on chrysotile in the elimination program of asbestos-related diseases.

– Explain and clarify the discrepancies in requiring the Ministry of Natural Resources and Environment to replace the Official Dispatch No. 1087/ BTNMT-TCMT dated 15 May 2014 to the Official Dispatch No. 2226/ BTNMT-TCMT dated 30 May 2014 (See Attachments) and stop repeating similar action due to its in transparency, dishonesty, lack of scientific and legal basis. Such action violates work ethics and causes tremendous economic loss to enterprises and jobs of workers in AC roof sheet production.

d) The Ministry of Science and Technology forms an inspection team to investigate the actual application results from 2004 to 2018 of the national scientific research projects KC-06 “Research, design, manufacture and experiment production chains of non-asbestos roof sheets with a capacity of 500,000 m2/year” and a state-level project KC.03. DA 03 / 11-15 “Improve technology for production non-chrysotile corrugated and flat roof sheets with a capacity of 3 million m2/year” reports objectively and fairly to the Prime Minister.

6.3. Proposing the leaders of the Party, Government and National Assembly to instruct the General Confederation of Labor, Vietnam Union of Science and Technology Associations, and experts to comply with the provisions of the Vietnamese law on conditional business of chrysotile when commenting, recommending and criticizing policies related to chrysotile; objectively and scientifically evaluate the toxicity of chrysotile; provide scientific and practical evidences; compare the toxicity of chrysotile during 55 years in Vietnam with other hazardous substances and industries such as cigarettes, peptides, preservatives, weight gainers, alcohols, other fields of stone exploitation, mining (coal, metal minerals), metallurgy, chemicals, transport, construction and actual use of chrysotile in regional countries and the world to have a scientific, objective and fair view of chrysotile application in roof sheets production.

6.4. Recommending the Central Propaganda and Training Commission to direct media agencies to report honestly so that people can understand the true nature of issue, avoid misleading and distorted information which causes public confusion, create a negative effect on AC roof sheets industry, national economy, especially political and social instability.

6.5 Requesting the Government to continue allowing eligible enterprises to use chrysotile in roof sheets production.

Sincerely thank.

 

Received places:

– As above;

– Achieved: VNRA.

 

 

 

 

 

ON BEHALF OF EXECUTIVE BOARD

PRESIDENT

 

 

 

Dr. Vo Quang Diem

 

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