10 July 2008
CR sends letter to OSWER (US EPA) re: strong disagreement with asbestos risk assessment methodologyA letter expressing the Collegium Ramazzini's strong disagreement with the draft report “Proposed approach for estimation of bin-specific cancer potency factors for inhalation exposure to asbestos” was sent by Dr. Morando Soffritti to the Office of Solid Waste and Emergency Response (OSWER) of the U.S. Environmental Protection Agency on July 10, 2008. The Collegium Ramazzini statement “Call for an international ban on asbestos” was enclosed.
10 July 2008
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
I submit this letter in reference to the June 12, 2008 draft report of the Office of Solid Waste and Emergency Response (OSWER) of the U.S. Environmental Protection Agency entitled “Proposed approach for estimation of bin-specific cancer potency factors for inhalation exposure to asbestos”.
On behalf of the President of the Collegium Ramazzini, Dr. Philip J. Landrigan and its 180 elected Fellows in countries around the world, I am writing to express the Collegium’s strong disagreement with the above document produced by the OSWER. We consider the approach that is proposed in this document will have the effect of unjustifiably diminishing the regulatory level of concern that is directed to control of exposures to chrysotile asbestos. We are of the strongly held scientific opinion that any relaxation of regulatory concern around chrysotile will result in increased human exposures to carcinogenic chrysotile asbestos worldwide and that these exposures will result in suffering, disease and death caused by asbestosis, lung cancer, malignant mesothelioma and other asbestos-related cancers. The Collegium Ramazzini considers this document an affront to both good science and to morality.
The Collegium Ramazzini is an international academy of 180 scientists from 35 countries, experts in environmental sciences and occupational health. The mission of the Collegium Ramazzini is to advance the study of occupational and environmental health issues and to be a bridge between the world of scientific discovery and the social and political centers which must act on the discoveries of science to protect public health. The Collegium has published the attached statement calling for a worldwide ban on all uses of all forms of asbestos, including chrysotile asbestos. It is indeed well documented, and referenced in this statement, that chrysotile is a proven carcinogen in both animal and human studies.
The Collegium Ramazzini questions why the Office of Solid Waste and Emergency Response would endorse a risk assessment model that would show significantly different risks from chrysotile and the amphiboles. It is the opinion of the Collegium Ramazzini that this model contains significant and fundamental flaws and that the results will be completely unreliable and subject to misuse and abuse.
The Collegium Ramazzini urges the OSWER to carefully consider the opposition of independent scientists when evaluating this proposal.
Dr. Morando Sofritti
Attachment 1: Collegium Ramazzini Statement “Call for an international ban on asbestos”