Naturally occurring asbestos: a recurring public policy challenge

Abstract

The potential environmental hazards and associated public health issues related to exposure to respirable dusts from the vicinity of natural in-place asbestos deposits (commonly referred to as naturally occurring asbestos, NOA) have gained the regulatory and media spotlight in many areas around the United States, such as Libby, MT, Fairfax County, VA, and El Dorado Hills, CA, among others. NOA deposits may be present in a variety of geologic formations. It has been suggested that airborne asbestos may be released from NOA deposits, and absent appropriate engineering controls, may pose a potential health hazard if these rocks are crushed or exposed to natural weathering and erosion or to human activities that create dust. The issue that needs to be addressed at a policy level is the method of assessing exposures to elongated rock fragments ubiquitous in dust clouds in these same environments and the associated risk. Elongated rock fragments and single crystal minerals present in NOA have been construed by some as having attributes, including the health effects, of asbestos fibers. However, the Occupational Safety and Health Administration (OSHA), Mine Safety and Health Administration (MSHA), and the Consumer Products Safety Commission (CPSC) found that the scientific evidence did not support this assumption. As in many environmental fields of study, the evidence is often disputed. Regulatory policy is not uniform on the subject of rock fragments, even within single agencies. The core of the issue is whether the risk parameters associated with exposures to commercial asbestos can or should be applied to rock fragments meeting an arbitrary set of particle dimensions used for counting asbestos fibers. Inappropriate inclusion of particles or fragments results in dilution of risk and needless expenditure of resources. On the other hand, inappropriate exclusion of particles or fragments may result in increased and unnecessary risk. Some of the fastest growing counties in the United States are in areas where NOA is known to exist and therefore this issue takes on national significance. This ongoing national dilemma has raised public and business concerns. There has been continuing political and scientific debate and widespread miscommunication over perceived versus actual health risks, the validity of various analytical sampling and testing methods, the questionable necessity and escalating costs of remediation procedures, and the combined negative impact on numerous commercial and public interests. Thus, conflicting research and regulatory positions on the distinctions between and hazards of true asbestos and ordinary rock fragments is all that is presently available to the public until the differing scientific communities and government agencies arrive at a consensus on these issues. The risk assessment methodology and the analytical technology needed to support inferences drawn from existing research are available, but have not been organized and implemented in the manner needed to resolve the NOA controversy. There should exist nationally adopted and peer-reviewed NOA standards (developed jointly by the scientific community, health risk professionals, and government regulators) that establish: (1) a scientific basis for risk evaluation and assessment of NOA and rock fragments; (2) accepted analytical protocols for determining if NOA actually exists in a given area and for separating NOA from related non-asbestos rock fragments and single crystal minerals; and (3) effective public policies for managing NOA, minimizing potential hazards, and protecting public health. This article will review some of the key issues involved with the current NOA debate, propose improved analytical methodologies, describe potential solutions for dealing with NOA, and outline the benefits to be gained by creating a practical national NOA public policy.