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Making India free of incurable hazardous asbestos related diseases & UN’s Rotterdam Convention

Written By mediavigil on Wednesday, April 05, 2017 | 1:17 AM

 ToxicsWatch Alliance (TWA)


Shri Ananth Kumar,
Union Ministry of Chemicals & Fertilizers
Member, Cabinet Committee on Economic Affairs 
Government of India
New Delhi

Date: April 4, 2017

Subject- Making India free of incurable hazardous asbestos related diseases & UN’s Rotterdam Convention
Dear Shree Kumar Jee,
With due respect ahead of the 8th Conference of the Parties (COP) of Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals in International Trade to be held during 24 April–5 May 2017 in Geneva, this is to draw your urgent attention towards the most recent paper titled, Pleuroperitoneal Mesothelioma: A Rare Entity on 18F-FDG PET/CT published in Indian Journal of Nuclear Medicine, authored by researchers from Department of Nuclear Medicine, All India Institute of Medical Sciences (AIIMS), New Delhi and Department of Radiodiagnosis, AIIMS (2017, January-March; 32(1): 75–76 issue). This paper authored by Dr Shamim Ahmed Shamim et al provides credible information about an asbestos related disease of a 40-year-old-female without any history of occupational asbestos exposure presented with histologically proven malignant pleural mesothelioma. Malignant mesothelioma is a rare tumor that originates from the cells lining the mesothelial surfaces, including the pleura, peritoneum, pericardium, and tunica vaginalis. (The other co-authors of the paper are Dr Manas Kumar Sahoo, Dr Anirban Mukherjee, Dr Girish, Dr Kumar Parida, Dr Krishan Kant Agarwal, Dr Chandrasekhar Bal, Dr Madhavi Tripathi and Dr Chandan Jyoti Das).  The paper is attached.
We are quite alarmed to note that Cabinet Committee on Economic Affairs, Government of India does not include Ministers of Consumer Affairs, Health, Labour, and Environment. It is hoped that despite such a structural constraint myopic commercial considerations will not triumph over gnawing concerns related to consumers, public health, workers, and environment.
We submit that an earlier paper titled Pleural mesothelioma: An unusual case diagnosed on pleural fluid cytology and immunocytochemistry was published in Diagnostic Cytopathology, Volume 37, Issue 7, pages 509–512, July 2009. The abstract of the paper states, “Mesothelioma is a rare neoplasm with relationship to occupational and environmental exposure to asbestos. Its accurate and early diagnosis is often difficult. We present an unusual clinical presentation and diagnostic dilemma in a 30-year-male, who presented with neck pain and diffuse edema of left upper limb. The color Doppler ultrasound revealed venous thrombosis. The right supraclavicular lymph node biopsy revealed a poorly differentiated carcinoma. The patient had mild bilateral pleural effusion, the characteristic cytomorphological features of mesothelioma on fluid cytology were helpful in establishing the diagnosis.” This paper was co-authored by Dr V K Arora, Dr S Aggarwal, Dr S Mathur, Dr G K Rath and Dr P K Julka from the Department of Pathology, AlIMS.
We submit that National Institute of Occupational Health (NIOH), Ahmedabad, Gujarat recommended compensation for two workers employed in Gujarat Composites Limited who were certified to be suffering from asbestosis. This has been revealed in a reply given by Government of Gujarat. A letter of Chief Inspector of Factories, Gujarat State dated December 24, 2002 in the matter of execution of the order of Supreme Court in Writ Petition (Civil) No. 206 of 1986 categorically reveals that two workers of Gujarat Composites Ltd were confirmed for Asbestosis, an incurable lung disease by NIOH. The workers were (1) Shri Hazarilal Manraj and (2) Shri Sahejram B Yadav. The letter recommended compensation of Rs 1 lakh as per the Court order but till date the same has not been given. This and many such cases conclusively establish the hazards from asbestos. Influence of the asbestos industry becomes quite obvious when Government turns a blind eye to such glaring official facts.  This is also a clear case of contempt of court by the asbestos based company. It may be noted that Gujarat Composite Ltd (formerly named Digvijay Cement Company) appears to be attempting to hide behind myriad corporate veils by changing names and by outsourcing its work.
The attached letter demonstrates that white chrysotile asbestos is a hazardous substance which causes asbestos related incurable diseases.     
We submit that these papers and the recommendation of NIOH indicates that significant health/environment hazards resulting from the use of asbestos.
These papers are relevant to the recommendation by the UN's Chemical Review Committee for listing in Annex III, wherein the COP has to take a final decision on inclusion of white chrysotile asbestos in Annex III at the COP meeting of Rotterdam Convention during April–May 2017.
We submit that the following countries have taken cognizance of the hazardous nature of all kinds of asbestos including white chrysotile asbestos:  1) Algeria, 2) Argentina, 3) Australia, 4) Austria, 5) Bahrain, 6) Belgium, 7) Brunei, 8) Bulgaria,  9) Chile, 10) Croatia, 11) Cyprus, 12) Czech Republic, 13) Denmark, 14) Egypt, 15) Estonia, 16) Finland, 17) France, 18)  Gabon, 19) Greece, 20) Germany, 21) Gibraltar, 22) Hungary, 23) Honduras, 24) Iceland, 25) Iraq, 26) Ireland, 27) Israel, 28) Italy, 29) Japan, 30) Jordan, 31) Kuwait, 32) Latvia, 33) Luxembourg, 34) Lithuania, 35) Mauritius, 36) Mozambique, 37) Malta, 38) Netherlands, 39) New Caledonia, 40) New Zealand, 41) Norway, 42) Oman, 43) Portugal, 44) Poland, 45) Qatar, 46) Romania, 47) Saudi Arabia, 48) Sweden,  49) Switzerland, 50) Serbia, 51) Seychelles, 52) Slovakia, 53) Slovenia, 54) South Africa, 55) South Korea, 56) Spain, 57) Turkey, 58) Uruguay and 59) United Kingdom. We can learn from them in this regard.                      
We wish to draw your immediate intervention to make India’s capital free of harmful asbestos based products in view of the statement of Shri Anil Madhav Dave, Union Minister of Environment, Forest & Climate Change in an interview with The Times of India said “Since the use of asbestos is affecting human health, its use should gradually be minimised and eventually end. As far as I know, its use is declining. But it must end…” (Source: Will look for alternatives to carcinogenic asbestos: Environment Minister. August 15, 2016, http://timesofindia.indiatimes.com/india/Will-look-for-alternatives-to-carcinogenic-asbestos- Mantri/articleshow/53703528.cms)
This statement of the minister in keeping with the 19 page long Vision Statement on Environment and Human Health of the Central Government states ‘4.3.1 Environmental epidemiological studies are required to be carried out near to industrial estates and hazardous waste disposal sites to estimate the extent of health risks including from asbestos. Alternatives to asbestos may be used to the extent possible and use of asbestos may be phased out’.” The relevant URL of Vision Statement on Environment and Human Health is available at www.envfor.nic.in/sites/default/files/visenvhealth.pdf
In such a backdrop, we submit that the ‘Study of Health Hazards / Environmental hazards resulting from use of Chrysotile variety of Asbestos in the country’, carried out by NIOH is highly questionable. It has been admitted in the Indian Parliament. It may be noted that “The study has no scientific credibility,” stated Dr. Philip Landrigan, President of the Collegium Ramazzini and Dean for Global Health, Icahn School of Medicine, Mount Sinai, New York. “It is flawed in the design, methodology and interpretation of the results,” he added. 

We submit that photos in the study show some workers wearing a cotton scarf tied around their face as their only “safety equipment”.  The study also shows workers weaving asbestos cloth. This is one of the most hazardous uses of asbestos.

The Statement of scientists on the ‘scientific’ study by NIOH reads: “We would like to strongly state that the ‘claim’ being made by the government of India regarding the ‘safety’ of Chrysotile asbestos is unacceptable to any credible scientists or scientific community. The world scientific community has overwhelmingly concluded that Chrysotile asbestos causes deadly diseases, such as asbestosis, mesothelioma and lung and other cancers, and that it cannot be safely used.” It concludes saying, “We therefore request the Government of India to withdraw the NIOH study, which does not hold up to any credible scientific scrutiny and do the right thing by supporting the listing of Chrysotile asbestos at the upcoming UN conference.”

We submit that the Indian Council for Medical Research (ICMR) Annual Report 2011-2012 reported the “Study of Hazards/Environmental Hazards resulting from use of Chrysotile variety of asbestos in the country (Ministry of Chemicals & Fertilizers, GOI)” as having been done. The Director, NIOH had sent a revised proposal on June 22, 2005 to Under Secretary, Department of Chemicals and Petrochemicals, Ministry of Chemicals and Fertilizers, Government of India to conduct the study. It is a matter of parliamentary record that two ministers, namely Labour Minister and Environment Minister have informed the Parliament that this study was conflict of interest ridden. The reply of the ministers is attached.  

It is germane to inform you that we (ToxicsWatch Alliance) got a reply from Shri R N Jindal, Union Ministry of Environment & Forests based on Department of Chemicals and Petrochemicals (DCPC)’s note dated June 18, 2013 on the issue of Government of India’s position on hazardous substance chrysotile asbestos at the Sixth Conference of Parties of (CoP-6) of the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade held during April 28-May 10, 2013 in Switzerland. The reply and the note based on NIOH study are attached because it is apparent that the same note is guiding the position of the focal ministry even in 2017.

The seven-page long note of the Department of Chemicals and Petrochemicals (DCPC), Union Ministry of Chemicals and Fertilizers on the subject of Chrysotile Asbestos titled ‘Department of Chemicals and Petrochemicals’ View on the use of Chrysotile Asbestos” in the country’ was shared with ToxicsWatch Alliance (TWA) by the Union Ministry of Environment & Forests.

We submit that MoEF’s contention based DCPC’s note stating that “On the basis of the said note, the listing of Chrysotile Asbestos under Annex ‘A’ of Rotterdam Convention at CoP-6 during April 28th -May 10th 2013 at Geneva could not be supported” was/is misplaced because even this questionable study did not state that white chrysotile asbestos is non-hazardous.  

Having carefully read the note of the ‘line department’, i.e. Department of Chemicals and Petrochemicals (DCPC), Union Ministry of Chemicals and Fertilizers on the subject chrysotile asbestos, we submit that the note of the DCPC reveals that it has failed to understand the purpose of the Rotterdam Convention and ignorance about the objective of the Convention.

We submit that the note is irrelevant from the point of view of the objective of the Convention for which it was prepared. While one disagrees with the findings of the conflict of interest ridden study conducted by the NIOH, it is evident that even this study does not state that chrysotile asbestos is not a hazardous chemical.

We submit that had NIOH study concluded that Chrysotile Asbestos is not a hazardous chemical it may have become relevant. But even then it would have been legally unsustainable because under Indian laws chrysotile asbestos is a hazardous chemical.  

We strongly disagree with the concluding sentence of the DCPC’s note saying, “In view of the above, India may take a stand in the next CoP meeting of Rotterdam Convention for not inclusion of chrysotile asbestos in Annexure-III of Convention.   
We submit that the flawed conclusion of the note titled ‘Department of Chemicals and Petrochemicals’ View on the use of Chrysotile Asbestos” in the country’ is quite stark and will not stand scrutiny of logic.

We submit that that there was strong objection at the unethical and immoral act of inclusion of Mr. Vivek Chandra Rao Sripalle of Asbestos Cement Products Manufacturers’ Association (ACPMA), India in the Provisional list of participants at the Technical workshop on chrysotile asbestos in Geneva, Switzerland in March 2015. An official on condition of anonymity that officials feel humiliated when they have to take orders from likes of ACPMA.

We submit that in a letter to Union Ministry of Environment & Forests (MoEF), on behalf of ToxicsWatch Alliance (TWA), we had shown how Indian delegation’s position at the sixth meeting on UN's Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade which concluded on May 10, 2013 with regard to asbestos was/is contrary to Indian laws in practice. Our submissions to the Ministry were responded and clarifications provided, which revealed that the MoEF was misled by Union Ministry of Chemicals which in turn was misled by Asbestos Cement Products Manufacturers’ Association (ACPMA), which had funded the questionable study by the NIOH. 

We submit that ACPMA had overwhelmed and misled the Indian delegation making the Indian delegation ignore the fact that Asbestos is listed as a hazardous substance under Part II of Schedule-I of the Manufacture, Storage and import of Hazardous Chemical Rules, 1989 under the Environment (Protection) Act, 1986 provides the List of Hazardous and Toxic Chemicals. This list has 429 chemicals. Asbestos is at the serial no. 28 in the list. This Rule and the list is available on the website of Union Ministry of Environment & Forests.

We submit that even then the Indian delegation included asbestos industry lobbyists like Mr. Vivek Chandra Rao Sripalle, ACPMA. The ACPMA’s influence on the Indian government delegation’s stance is quite manifest. It also merits attention as to whether the industry representatives went to this UN conference on their own expense or government sponsored their visit. ACPMA consists of 20 big firms and 68 manufacturing units, of which top six players holding 87 per cent of the market share.

We submit that had ACPMA not overwhelmed the Indian delegation, the Indian position would have been in keeping with its Inventory of Hazardous Chemicals Import in India that lists ‘asbestos’ at serial no. 26 as one of the 180 hazardous chemicals in international trade which is imported in India. This inventory was prepared by Central Pollution Control Board (CPCB), under Union Ministry of Environment & Forests, Govt. of India prepared in September, 2008 with a foreword September 24, 2008 by Shri J. M. Mauskar, the then Chairman, CPCB and Additional Secretary, Union Ministry of Environment & Forests This was done pursue of Government of India’s “Manufacture, Storage, and Import of Hazardous Chemicals (MSIHC) Rules, 1989” under the Environment (Protection) Act, 1986. According to these Rules, any person responsible for importing hazardous chemicals in India is to provide the data of import to the concerned authorities, as identified in Column 2 of Schedule 5 to the Rules. The CPCB “has been identified as one of such Authorities. In order to study the inventory of Hazardous Chemicals being imported by various categories of industrial units in India, the data provided by these industrial units to the Central Pollution Control Board (CPCB) have been compiled.” It is scandalous as to why did the Indian delegation took a position inconsistent with the Manufacture, Storage, and Import of Hazardous Chemicals (MSIHC) Rules, 1989.

We submit that even under Factories Act, 1948, the List of 29 industries involving hazardous processes is given under Section 2 (cb), Schedule First, asbestos is mentioned at serial no. 24.  The Act defines "hazardous process" as “any process or activity in relation to an industry specified in the First Schedule where, unless special care is taken, raw materials used therein or the intermediate or finished products, bye-products, wastes or effluents thereof would--(i) cause material impairment to the health of the persons engaged in or connected therewith, or (ii) result in the pollution of the general environment”.  This leaves no doubt that asbestos is a hazardous substance. The Act is available at:

We submit that promoters of white chrysotile asbestos like ACPMA who were planted in the Indian delegation made the government representatives take a position against human health and the environment and to put profit of the asbestos industry before gnawing public health concerns.

We submit that on June 22, 2011 Indian delegation led by Ms. Mira Mehrishi, Additional Secretary, had supported the listing of Chrysotile asbestos as a hazardous chemical substance at the fifth meeting on Rotterdam Convention amidst standing ovation. TWA had taken the opportunity of congratulating the government but the about turn in May 2013 was a sad let down.

It is reliably learnt that officials and scientists who go to such UN meetings feel humiliated when the industry representatives give them directions instead of the senior government officials or ministers. The UN meet on hazardous chemicals creates a rationale for insulating government officials from undue and motivated industry influence else they will be obliged to act like parrots. The Cabinet Committee on Economic Affairs (CCEA) must factor in the far reaching implications for public health before defending the indefensible hazardous asbestos industry. The day is not far when members of CCEA too will be held liable for their acts of omission and commission as is happening in more than 50 countries that have banned all kinds of asbestos.  

In keeping with Indian laws when the UN’s Chemical Review Committee of Rotterdam Convention recommended listing of white chrysotile asbestos as hazardous substance it is incomprehensible as why Indian delegation opposed its inclusion in the UN list. The only explanation appears to be the fact that the Indian government delegation did not have a position independent of the asbestos industry’s position which has covered up and denied the scientific evidence that all asbestos can cause disease and death.

We submit that meanwhile, an Advisory Committee of Union Ministry of Labour has been set up to implement Hon’ble Supreme Court order issued on January 27, 1995 and reiterated on January 23, 2012.

We submit that global experience underlines that even early industry-funded studies showed a causal relationship between asbestos exposure and cancer. Had this been made known to the public it could have prevented countless deaths but the asbestos industry made the conscious decision to protect their profits instead and choose to keep this information hidden from the public. India’s asbestos industry is following the same path.  

As a consequence, although millions of Indian lives are being lost and millions are being exposed to the killer fibers of white chrysotile asbestos, no government agency or company is being held liable due to political patronage which becomes quite glaringly visible when ACPMA is included as part of the delegation.

While on a visit to New Delhi, Dr Alec Farquhar, the then Managing Director, Occupational Health Clinics for Ontario Workers, Canada said, “We now have around 500 asbestos cancer cases every year in Ontario from a population of 13 million. If you (India) continue on your current path, you will multiply our death count by 100 times. That would be 50, 000 Indian workers dying every year from asbestos. In Ontario, we learned that safe use of asbestos is impossible. I urge you from the bottom of my heart, please do not make the same mistake as we made in Canada. Stop using asbestos and use a safe alternative.” It is clear that lack of documentation and lack of environmental and occupational health infrastructure does not mean lack of victims of asbestos related diseases.

It has been estimated that one person dies from mesothelioma for every 170 tons of asbestos consumed. WHO estimates we have107,000 deaths worldwide per year from occupational exposure to asbestos. If non occupational exposure is added it reaches a figure of about 120,000 deaths. Average world consumption/year 30-60 years ago was -- looks like3/2 of what it is now (2 million metric tons/year). Give India its share of that based on its share of global consumption. At 300,000 tons in 2013, that's about 18,000 deaths (15% of 120,000).  Asbestos diseases have a very long incubation period. So if you are exposed today to an asbestos fibre, you are likely to get the disease in next 10-35 years. Asbestos is like a time bomb to the lungs and Indians will suffer the most. If it is banned today that does not mean people will not suffer. Because of past usage people will continue to suffer from these diseases.

We submit that the very existence of ACPMA is highly problematic and very dubious. ACPMA which faced charges of cartelization by the Competition Commission of India is registered under The Societies Registration Act, 1860 and it claims to be a non-profit organization. Is the asbestos industry a non-profit organization? They make completely dubious and baseless claims. They have put profit ahead of public health. These associations appear inhuman, cruel and have a deviant behavior. The members of ACPMA all await the fate of Kubota Corporation.

We wish to draw your attention towards the verdict of five judges of Japan’s Supreme Court of February 17, 2015 that has upheld a ruling that found asbestos used at a plant of Kubota Corporation caused fatal mesothelioma in a man who lived near the plant and ordered the company to pay ¥31.9 million in damages to his relatives. The petitioners were relatives of Kojiro Yamauchi, who died at age 80 after working for two decades about 200 meters from the Kubota plant in Amagasaki, Hyogo Prefecture. His relatives and those of Ayako Yasui, who died at age 85 having lived about 1 km from the plant, sought damages from both Kubota and the government. In October, 2014 this Supreme Court ruled that the government was responsible for failing to protect workers from exposure at asbestos factories in Sennan, Osaka Prefecture.
It is noteworthy that Japan has banned asbestos of all kinds including white chrysotile asbestos.

We also wish to draw your attention towards the fact that our neighbor Nepal has become the first country in South Asia which going in the direction of banning asbestos. We were part of the efforts in raising awareness in Nepal.

We submit that in January 1995, while passing the judgment for the asbestos case file by the Consumer Education & Research Centre (CERC) (case details: http://indiankanoon.org/doc/1657323/),  Hon’ble Supreme Court of India directed all asbestos factories to keep the health records of their workers for 40 years and/or 15 years after their retirement. ACPMA members have failed to maintain their employee’s heath records on their websites.

We submit that in August 2003, during the previous NDA led government regime, the Union Health Minister had informed the parliament that asbestos causes incurable lung diseases (such as asbestosis, lung cancer, etc).

We submit that Indian Navy officials have rightly objected to presence of asbestos in aircraft carrier Admiral Gorshkov which was inducted into the Indian Navy as INS Vikramaditya after asbestos decontamination. 

We submit that Union of India’s Budget 2011-12 had made reference to asbestos related diseases by including it under the Rashtriya Swasthya Bima Yojana to cover ‘unorganized sector workers in hazardous mining and associated industries like asbestos etc”.

We submit that during Internal Emergency declared in June 1975, the ruling party and its acolytes had proposed to put opposition leaders in jails which had asbestos roofs because it was harmful to health.

We submit that there are fibre substitutes that have been evaluated by WHO are listed in the Summary Consensus Report of WHO Workshop on Mechanisms of Fibre Carcinogenesis and Assessment of Chrysotile Asbestos Substitutes.

We submit that in the 32rd year of Bhopal disaster, asbestos industry should pay heed to the way asbestos companies have gone bankrupt in the western countries. They should join hands and create a compensation fund for victims. Dow Chemicals Company which refuses to own the liability for Bhopal disaster caused by Union Carbide Corporation (UCC) in India has owned the UCC’s asbestos related liabilities and announced a compensation fund of 2.2 billion dollars for the victims. In Europe, tycoons and ministers are facing criminal charges and imprisonment for their act of knowing subjecting unsuspecting people to killer fibers of asbestos. The future is no different for Indian culprits.
We submit that a Technical Committee set up by Union Ministry of Industry examined the health impact of asbestos in 1994. The Office Memorandum NO.6 (6)/94 - Cement, (September 1, 1994) reads: "The Department has generally not been recommending any case of Industrial License to any new unit for the creation of fresh capacity of asbestos products in the recent past due to the apprehension that prolonged exposure to asbestos leads to serious health hazards".   
We submit that by letter dated 9th July, 1986  from Union Ministry of Steel, Mines & Coal, Government of India with reference no. 7/23/84-AM-III/AM-VI there is a stay on grant of new mining lease for asbestos mineral and renewal of the leases. Reiterating the same in June 1993, central government stopped the renewal of existing mining leases of asbestos. The mining activity was banned by Union Ministry of Mines. As a result at present no permission is being given for new mining lease of asbestos mineral and no lease is being renewed. At present no lease of asbestos mineral is approved/or in force in the country.  It is strange that while mining of asbestos is banned in the country due to adverse health impact, the same is being imported from Russia, Kazakhstan, Kyrgyzstan and Zimbabwe. It high time government stopped practicing such untenable policies displaying manifest double standards.
In a bizarre act while Government of India has technically banned asbestos mining, it continues to allow import and export of asbestos. "In view of the deleterious effect of asbestos mining on health of the  workers, the government has ordered the State governments in 1986 not to grant any new mining lease for asbestos (including Chrysotile variety) in the country" as per Government of India’s letter. Government must be made make India asbestos free by rectifying the irrationality of banning mining of asbestos but continuing its trade.
We submit that following vibrant struggle in villages of Muzaffarpur and Vaishali in Bihar and Bargarh in Odisha stopped the establishment of asbestos based plants.  There are struggles going in Bhojpur, Bihar against such heavily polluting factories and the Bihar State Pollution Control Board has cancelled their permissions to operate these factories because of violation of environmental laws. 
We submit that three cases of asbestos related diseases i.e. Mesothelioma have been reported from among the workers of employed in the factory of Hyderabad Industries Limited, Sanathnagara, Hyderabad in Andhra Pradesh. These workers have died due to the disease. These workers were: 1) Shri N Chandra Mouli, 2) Shri Sher Khan and 3) Shri Rama Chandraiah. This was revealed in an affidavit filed by Shri T Narayana Reddy, Special Officer Office of Advocate-on-record, Andhra Pradesh Legal Cell, New Delhi in the Hon’ble Supreme Court. This company in question may be asked to file a report on total number of workers employed by it and their health status including a report about the three above mentioned workers.
We submit that both workers and consumers are at fatal risk from the killer asbestos fibers through the life cycle of the asbestos based products. 
We submit that as per World Health Organisation (WHO), " All types of asbestos cause lung cancer, mesothelioma, cancer of the larynx and ovary, and asbestosis (fibrosis of the lungs). Exposure to asbestos occurs through inhalation of fibres in air in the working environment, ambient air in the vicinity of point sources such as factories handling asbestos, or indoor air in housing and buildings containing friable (crumbly) asbestos materials." It underlines that several thousands of deaths can be attributed to other asbestos-related diseases, as well as to non-occupational exposures to asbestos.

WHO recommends the following public health actions for elimination of asbestos-related diseases:-     
1.      -recognizing that the most efficient way to eliminate asbestos-related diseases is to stop the use of all types of asbestos;    
2.      -replacing asbestos with safer substitutes and developing economic and technological mechanisms to stimulate its replacement;    
3.      -taking measures to prevent exposure to asbestos in place and during asbestos removal (abatement), and;    
4.      -improving early diagnosis, treatment, social and medical rehabilitation of asbestos-related diseases and establishing registries of people with past and/or current exposures to asbestos.

We wish to draw your attention towards the interview of Dr. Frank, Professor of Public Health and Chair Emeritus of the Department of Environmental and Occupational Health at the Drexel University School of Public Health, about the international research on asbestos he’s championed since the early 1990s. He asserts, “The people who do treatment research are oncologists and radiotherapists and surgeons, so they’re not always as concerned with identifying what the cause was. That’s what I do. I identify the cause of things.”  The interview is available at https://www.mesothelioma.com/blog/authors/staff/asbestos-around-the-world-an-interview-with-dr-arthur-frank.htm

It may be noted that in our country, the government does not record cases of mesothelioma, and thus proclaims no one in the country develops the disease. Dr. Frank asserts, “a lack of data does not mean a lack of disease.” In fact, when speaking to a doctor from a major cancer hospital in Mumbai, Dr. Frank learned that, in just one year, there were 32 cases of mesothelioma in that hospital alone. “A lot of the asbestos cement factories — a major use of asbestos in India — are owned by members of parliament,” he said. “You can draw your own conclusions.”

We wish to draw your urgent attention towards a Statement calling on the Government of India  to withdraw a discredited scientific study on chrysotile (white) asbestos and to stop blocking the listing of chrysotile asbestos as a hazardous substance at an upcoming UN meeting.

We submit that it is eminently consistent with the principle of prior informed consent for India which imports White Chrysotile Asbestos from countries like Russia, Brazil, Zimbabwe, Kazakhstan and others to receive the information to assess whether it has the ability to safely use this substance or products containing it. The fact remains that the Convention is about prior informed consent about trade in hazardous chemicals and not about banning any hazardous substance.

We submit that India should not allow itself to be misled by asbestos producers like Russia and Kazakhstan in this regard now that Canada has rightly stopped mining of white chrysotile asbestos almost like India due its “deleterious” impact on health. 

In view of the above, we demand that vested interests like ACPMA should not be included in the Indian delegation and it must support its inclusion in the Annexure III of the Rotterdam Convention at the UN meetings in April- May, 2017 in Geneva.  

Therefore, we urge you to take cognisance of the findings of AIIMS, Chemical Review Committee, WHO and Prof. Frank besides the Statement of Scientists and the concern of the Union Environment Minister in order to initiate action to deal with asbestos related diseases of present and future generations in right earnest.

We will be happy to meet you and learn about your action to protect consumers, public health, workers, and environment in the face of myopic profit driven lobbying.  

Warm Regards
Dr Gopal Krishna
ToxicsWatch Alliance (TWA)
Mb: 08227816731, 09818089660
www.asbestosfreeindia.org, toxicswatch.org

Smt. Sushma Swaraj, Member, Cabinet Committee on Economic Affairs 
Shri Rajnath Singh, Member, Cabinet Committee on Economic Affairs 
Shri Arun Jaitley, Member, Cabinet Committee on Economic Affairs 
Shri Suresh Prabhu, Member, Cabinet Committee on Economic Affairs 
Shri Nitin Gadkari, Member, Cabinet Committee on Economic Affairs 
Shri M. Venkaiah Naidu, Member, Cabinet Committee on Economic Affairs 
Shri Ravi Shankar Prasad, Member, Cabinet Committee on Economic Affairs 
Shri Radha Mohan Singh, Member, Cabinet Committee on Economic Affairs 
Shri Ashok Gajapathi Raju, Member, Cabinet Committee on Economic Affairs 
Shri Harsimrat Kaur Badal, Member, Cabinet Committee on Economic Affairs 
Shri Dharmendra Pradhan, Special Invitee, Cabinet Committee on Economic Affairs 
Shri Piyush Goyal, Special Invitee, Cabinet Committee on Economic Affairs 
Smt. Nirmala Sitharaman, Special Invitee, Cabinet Committee on Economic Affairs 
Shri Anil Madhav Dave, Union Minister of State (Independent Charge), Environment, Forest and Climate Change
Chairman, Parliamentary Standing Committee on Commerce
Chairman, Parliamentary Standing Committee on Chemicals & Fertilizers
Chairman, Parliamentary Standing Committee on Health and Family Welfare
Chairman, Parliamentary Standing Committee on Labour
Chairman, Parliamentary Standing Committee on Committee on Science & Technology, Environment & Forests
Chairman, Parliamentary Standing Committee on Food, Consumer Affairs & Public Distribution
Chairman, Parliamentary Standing Committee on Industry
Chairman, Parliamentary Standing Committee on Finance
Chairman, Parliamentary Standing Committee on External Affairs
Chairman, Parliamentary Standing Committee on Defence
Shri Pradeep Kumar Sinha, Cabinet Secretary
Secretary, Union Ministry of External Affairs
Secretary, Union Ministry of Chemicals & Fertilizers
Joint Secretary (Chemicals), Department of Chemicals and Petrochemicals, Ministry of Chemicals and Fertilizers
"We may admire what he does, but we despise what he is."-referring to humans who act mechanically on instructions
-------Wilhelm von Humboldt, 1792

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