Impact on aggregates of regulating nonasbestos minerals as asbestos

Introduction On June 20, 1986, the Occupational Safety and Health Administration (OSHA) published revised asbestos exposure standards for general industry and construction. The standards reflect OSHA's attempt to adequately control workplace exposures to minerals it considers carcinogenic - minerals capable of causing or contributing to cancer. These standards specifically identify asbestos as: chrysotile, an asbestiform serpentine mineral; and the amphibole minerals amosite, crocidolite, tremolite asbestos, actinolite asbestos, and anthophyllite asbestos. Each of these has a more common nonasbestos mineral analog that exists in nature in a crystalline, blocky shape rather than the hair-like or fibrous shape of asbestos. The mineralogical names for three of these nonasbestos minerals are unique: antigorite for chrysotile, cummingtonite-grunerite for amosite, and riebeckite for crocidolite. The other three nonasbestos analogs do not have unique mineralogical names. They are simply designated as actinolite, tremolite, and anthophyllite without the word asbestos following their names. The 1986 OSHA standards not only cover exposure to the six asbestos minerals, they also cover specifically the nonasbestos forms of actinolite, tremolite, and anthophyllite (AT&A). The new standards regulate these minerals exactly like asbestos (OSHA, 1986). The construction aggregate industry views this as a major problem because these nonasbestos minerals are common amphibole rock-forming minerals in the earth's crust. They exist in small quantities over large areas of the United States (Kuryvial et al., 1974). These minerals, unlike asbestos, are not mined for a specific commercial purpose. They are unavoidable components in much of the aggregate used for construction throughout the US. They are also common in the gangue material of metallic ores. There are areas of the US where amphibole-bearing bed¬rock is common. Not every rock mass in these areas contain amphiboles, however. It does mean, though, that amphiboles are physically compatible with many of the rocks in those areas. And given the correct geochemical conditions, they will be present primarily in the nonasbestiform variety. In addition, these amphiboles will probably exist in the natural drainage system, sand and gravel deposits, stream sediments, lake shores, valley basins, or ordinary beach sand within these areas. There has been little quantification of nonasbestiform AT&A in dusts and soils in the US. This is not surprising since these nonasbestiform minerals are not commercially valuable. However, an example of the pervasive nature of these minerals can be found in a 1981 Geological Society of America publication where about 0.7% tremolite-actinolite was found in the desert dust in and around Tempe, AZ (Pewe, 1981). Since OSHA standards treat these common nonasbestos minerals as carcinogens in the same way as asbestos, large natural areas in the US are implicitly being labeled as hazardous by OSHA. When a substance is identified as a carcinogen, another OSHA standard comes into play, the Hazard Communication standard. There are also right-to-know laws in 9 states that essentially duplicate this federal standard. These standards require that a product containing 0.1% or more of an OSHA-designated carcinogen be labeled as such (OSHA, 1983). This means that much of the stone and sand gravel products occurring naturally and mined in the US could be labeled a carcinogen when, in fact, they are not. The National Stone Association (NSA) and the domestic construction and mining industries believe that OSHA has seriously erred. The NSA has studied the health, mineralogical, technical, economic, and legal basis for OSHA's action. These studies concluded that there is no justification for the agency regulating nonasbestos minerals as if they were asbestos. Health issues The preamble to OSHA's 1986 asbestos standard states that evidence for asbestos-like health effects from exposure to nonasbestiform varieties of AT&A is inconclusive (OSHA, 1986). The fact is, not only are the data inconclusive, they are nonexistent. During 1986-1987, NSA's occupational health and epidemiology consultant, Environmental Health Associates (EHA), reviewed all available health studies related to AT&A. EHA found evidence that malignancies in both experimental animals and humans are associated with the asbestos forms of these minerals. No experimental or epidemiological evidence was found that indicated such pathogenic effects occur from exposure to nonasbestiform varieties of these minerals. There are relatively few scientific studies of the health effects of exposure to nonasbestiform varieties of AT&A. In three different animal studies, exposure to either nonasbestiform tremolite or actinolite did not result in pulmonary fibrosis on in excess tu-