MERGING MINERALOGY WITH POLICY: WHAT REGULATORS NEED TO MAKE RATIONAL DECISIONS

The six minerals known commercially as asbestos are regulated by the Occupational Safety and Health Administration (OSHA); these regulations apply to industrially processed fibers in the workplace, but not to geologic occurrences of asbestos ore minerals. Research has revealed that the regulation of six asbestos products by their mineral names is inconsistent and inadequate, and to address this, the National Institute for Occupational Safety and Health (NIOSH) has drafted a working document titled Asbestos Fibers and Other Elongated Mineral Particles: State of the Science and Roadmap for Research. While NIOSH states that guidance for safeguarding worker health is not necessarily pertinent to the general population, the Environmental Protection Agency (EPA) has expressed a controversial intent to regulate geological occurrences of asbestiform minerals. However, there is currently no such roadmap for addressing the unique issues that burden any attempt to regulate non-occupational exposures in outdoor geologic settings. EPA activities in Libby, Montana, and Clear Creek Management Area and El Dorado Hills, California, have brought to light an urgent need to form a consensus among mineralogists, epidemiologists, and regulators on this delicate issue. Using the NIOSH roadmap as a basis for discussion, this presentation will provide an overview of the most pressing questions that need to be answered before any regulatory action is taken. Current debates include the issue of mineralogy versus morphology: is it the surface chemistry or the size and aspect ratio of fibers that cause illness; or both? Are there other species besides “the regulated six” that cause illness? Is there a difference in toxicology between exposures to commercial asbestos versus inhalation of unprocessed asbestiform mineral particles in the outdoors? How will investigators conduct relevant in vitro and in vivo studies? What methods will be used to detect and quantify potential exposures? How would an agency abate exposures to minerals that are likely to be found over vast areas of the United States? Input from mineralogists is necessary to answer all of these questions. Failure to produce a carefully considered, well-researched, and well-defined plan could have far-reaching negative impacts that would be difficult to reverse.