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I believe I've found the SNUR in question [0] and it seems to state that the EPA will consider uses of asbestos in construction: > Any Other Building Materials

by k1ns 8y ago

I believe I've found the SNUR in question [0] and it seems to state that the EPA will consider uses of asbestos in construction: > Any Other Building Materials (other than cement): Examples include insulation, plasters, mastics, textured paints (e.g., simulates stucco), and block filler paints (e.g., for coating masonry). It looks like they're wanting to open a pathway of discussion between potential manufacturers/importers of asbestos and the EPA for new business opportunities which apparently include new construction, the brake pads that go onto your vehicles, and the floor tiles in your home. This sounds insane to me. I don't want to live in a world where policymakers with no scientific background get to decide how they personally feel about proven carcinogens in my children's lives. They seem to literally be saying that they want to consider asbestos in construction projects as a significant new use despite the fact that using it in construction was previously proven to be unsafe. The comment date is quickly closing, please let your voice be heard. [0] https://www.regulations.gov/document?D=EPA-HQ-OPPT-2018-0159-0001 https://www.regulations.gov/document?D=EPA-HQ-OPPT-2018-0159... EDIT: If I'm confused and have linked something irrelevant, please let me know and I will redact.

makomk 8y ago
I'm pretty sure that's the right rule. What you're missing is that previously those weren't considered new uses of asbestos at all in the US because it had been used for those purposes prior to 1989. As I understand it, without this proposed rule it would in fact be perfectly legal for US companies to just go right ahead and use asbestos in those building materials without any kind of EPA pre-approval. Requiring them to seek out the EPA's approval first is actually tightening the rules. (There are only five pre-1989 uses of asbestos which were banned, and this isn't one of them.) The main reason no-one uses asbestos for this is probably that it's a liability and PR disaster zone. See in particular section III, which explains this all reasonably clearly.
- k1ns 8y ago
  Very well said, thanks for the clarification. I read through it several times and came away feeling two different ways about it simultaneously. 1) Like you said, I assumed this meant that they were installing themselves via the law instead of relying on the honor system. I think that's awesome news. 2) I don't trust them to act in the best interest of the masses when it comes to which uses they green light and which uses they shoot down. But that's 100% my opinion which is cynical in nature most of the time. As long as the EPA uses this power for good, I'm all for it. I am skeptical about their motives though (which is entirely subjective).

by k1ns 8y ago

makomk 8y ago

I'm pretty sure that's the right rule. What you're missing is that previously those weren't considered new uses of asbestos at all in the US because it had been used for those purposes prior to 1989. As I understand it, without this proposed rule it would in fact be perfectly legal for US companies to just go right ahead and use asbestos in those building materials without any kind of EPA pre-approval. Requiring them to seek out the EPA's approval first is actually tightening the rules. (There are only five pre-1989 uses of asbestos which were banned, and this isn't one of them.) The main reason no-one uses asbestos for this is probably that it's a liability and PR disaster zone. See in particular section III, which explains this all reasonably clearly.

k1ns 8y ago
Very well said, thanks for the clarification. I read through it several times and came away feeling two different ways about it simultaneously. 1) Like you said, I assumed this meant that they were installing themselves via the law instead of relying on the honor system. I think that's awesome news. 2) I don't trust them to act in the best interest of the masses when it comes to which uses they green light and which uses they shoot down. But that's 100% my opinion which is cynical in nature most of the time. As long as the EPA uses this power for good, I'm all for it. I am skeptical about their motives though (which is entirely subjective).