Responded by units: The Ministry of Construction

Official letter: No 25/ BXD - VLXD, dated: 2018-10-29

Responded contents:

1. Basing on development of the Project

Comments of the Ha Long Construction Material Co., Ltd:

"The Branch of Ha Long Construction Material Co., Ltd. realized that the proposal in the Project was not based on scientific and practical basis: the Ministry of Construction did not give any scientific and practical basis, but it mightbe listened following the conflicting and distorting allegations aimed for the benefit of replacing asbestos roofing sheets with other products, while the construction market demand using composite panels was huge ”

Comments of the Ministry of Construction:

1.1 Scientific basis

a) Research results published by the Ministry of Health

On the effects of chrysotile on human health, according to information from the Department of Health Environmental Management - Ministry of Health (2014), the viewpoint of removing asbestos-related diseases was stated in the resolution No. 60.26 in 2007 of the World Health Council (WHA) and the viewpoint of prevention of non-communicable diseases, including cancer in the Resolution 66.10, 2013 of WHA. In terms of health effects, the International Agency for Research on Cancer (IARC) classified asbestos as a carcinogen. In addition, according to this report, at least 107 thousand people have died from lung cancer, mesothelioma and asbestosis due to occupational exposure to asbestos. The use of amphibole asbestos (hereinafter referred to as blue and brown asbestos) has been prohibited under the Convention of the World Labor Organization (ILO) on the safety of asbestos use (No. 162) since 1986. White asbestos has remaineduse in construction materials, friction materials, textiles and other applications.

Representatives of the Department of Health Environmental Management recommends: There is no evidence of threshold for carcinogenic that effected of asbestos, including chrysotile. Therefore, the most effective way eliminating asbestos-related diseases is: (1) stoped using all types of asbestos; (2) provides information on alternative asbestos solutions to alternatives and develops economic and technological mechanisms to promote replacement; (3) takepreventive measures against asbestos; (4) strengthens early diagnosis, treatment and rehabilitation services for asbestos-related diseases and establishs registrations for people who had beenand / or being contactingto asbestos.

The Institute of Health and Environment - Ministry of Health hasinformed the IARC program and the process and way of implementation. This is a program to develop a monograph to conduct risk assessments, makes decisions on preventive measures, provides effective mail control programs and decides on options for public health. The chrysotile in the list of carcinogens is mentioned in this monograph. The report provides evidence of asbestos-related illness.

b) The study of Results published by the World Health Organization (WHO)

WHO has conducted numerous assessments of human health impacts related to exposure to chrysotile over the past 20 years. These assessments have concluded that all forms of asbestos including white asbestos causing cancer for humans, causing mesothelioma and cancer of the lung, larynx and ovaries. Chrysotile hasalsocaused non-malignant lung diseases that lead to decrease lung function (asbestosis). Many scientific studies have talked about the link between asbestos exposure and the undesirable health effects that have been identified along with a large number of studies in occupational settings.

IARC conclusions about lung cancer and mesothelioma:

There is enough evidence to cause lung cancer and mesothelioma in people with all types of asbestos including asbestos.

This is the IARC's most powerful way to describe the robustness of evidence.

1.2 Legal basis

The Decision No. 1469 / QD-TTg dated August 22, 2014 of the Government’s Prime Minister on Vietnam's construction materials development planning till 2020 with a vision to year;

The Document No. 7307 / VPCP-KGVX dated September 19, 2014 of the Government’s Office on the evaluation and control of the effects of chrysotile on human health;

The Document No. 7232 / VPCP-KGVX dated 11 July 2017 of the Government’s Office announcing the direction of the Government’s Prime Minister to assign the Ministry of Construction to preside over and coordinate with relevant ministries and agencies to assess the situation. using asbestos page in roofing production, propose specifically the roadmap to stop using chrysotile in accordance with finding alternative materials, meeting the requirements and affordability of people in difficult areas and report to the Prime Minister.

The Document No. 371 / VPCP-TH dated February 2, 2018 of the Government’sOffice, the Government’s Prime Minister assigned the Ministry of Construction to develop a scheme to study the construction of a roadmap to stop the use of chrysotilein in order tocease productionof asbestos roofing.

1.3 Practical basis

The removal of asbestos from products close to people is a common trend of the world. On August 5, 2014 WHO and ILO sent a letter to the Government’s Prime Minister of Vietnam on the prevention of asbestos-related diseases and expressed concern about the continued use of chrysotile in construction materials and produceother products in Vietnam.

According to WHO, the total number of countries updated to October 3, 2017 was 80 countries in which:

• 51 countries completely banned the use of asbestos1.

• 18 countries prohibit the majority of asbestos use2.

• 11 countries have not banned the use of asbestos3.

Among 51 updated countries that banned use of asbestos, many countries banned all types of asbestos, some initially banned the use of asbestos amphibole groups (blue and brown asbestos), then banned use chrysotile asbestos (white asbestos). There are countries that offer a dumb route but some countries immediately issue a ban on use without mentioning the roadmap. The roadmap to ban the use of asbestos by different countries is also different: Sweden 4 years, Denmark 3 years, Italy 2 years ...

About the consumption of asbestos in the world, the consumption of asbestos has decreased sharply over the years. Asbestos consumption in the UK was 143,000 tons in 1976, then gradually decreased to 10,000 tons in 1995. France imported about 176,000 tons of asbestos in 1976 and imports stopped in 1996 when France banned the use of asbestos. In Germany, the use of asbestos was about 175,000 tons annually from 1965 to 1975, then gradually reduced and banned from use at the end of 1993. As the use of asbestos was banned in the European Union, currently, asbestos was no longer available consumed in the UK, France and Germany. In Japan, asbestos consumption was about 320,000 tons in 1998 and continuously decreased by year, until 2005 only 5,000 tons / year. The use of asbestos was banned in Japan in 2012. In Singapore, the import of crude asbestos (only chrysotile) has decreased according to the roadmap from 243 tons in 1997 to 0 tons in 2001. In Philippines, the import of asbestos raw materials was about 570 tons in 1996 and reduced to 450 tons in 2000 and now stopp using.

 Although asbestos has not been banned in the United States, but because US law requires manufacturers to be responsible for coming to their products if harming users, the consumption of asbestos decreased from 668,000 tons in 1970. down 359,000 tons in 1980, 32 tons in 1990, 1.1 tons in 2000 and ton in 2010. Currently in the United States, asbestos is only used in the aerospace industry.

2. About the impact of asbestos on human health

Comments of Ha Long Construction Material Co., Ltd

Different opinions about chrysotile fibers in roofing sheets whether or not affectingpeople’s health that were still controversial. Although so, the studyof Ministry level was similar to that of Construction Hospital, the studying results of occupational health examination and labor environment measurement from 2008 to 2018, especially the study of the Department of Health Environmental Management - Ministry of Health on "Exposure to chrysotile-related diseases" conducted in 2009 to 2011, the results all shownedthat there wasno specific information to convince and prove the cause of the disease. occupation due to exposure to asbestos or use of asbestos construction roofing products.

Comments of the Ministry of Construction:

Studying results in Vietnam have shown that no serious effects of chrysotile on human health that have been found such as lung cancer, mesothelioma. However, it can be seen that studies conducted in Vietnam have not been long enough in some places in Vietnam. These studies have not yet applied intensive experiments, no studying results have been published on international medical journals. In addition, although studies in Vietnam and some foreign experts have not found evidence that chrysotile is harmful to human health, it is still recommended that dispersalasbestos control measures into the environmentare needed.

3. Regarding solutions ofsupporting enterprises

Comments of the Ha Long Construction Material Co., Ltd:

"In parallel with the introduction of a roadmap to stop using and terminating the production of asbestos roofing sheets, the Ministry of Construction did not propose specific solutions to support enterprises but still explicitly set the time for the termination of asbestos roofing productionfrom 2023, the point of view of the Ministry of Construction on this issue under the branch of Ha Long Construction Materials Co., Ltdwasunilateral that could lead to the consequences of eliminating enterprises and causing many workers who had to work hard due to losing their jobs ".

Comments of the Ministry of Construction:

The project does not aim to stop the production of cement roofing sheets but it is aimed to replace asbestos fibers with other non-toxic fibers in the mix, creats environmentally friendly roofing products. In terms of roofing technology, there is almost no change except for a few small improvements in technology parameters when using other fibers to replace asbestos fibers in the mix.

The draft Project provides specific tasks for the relevant ministries to support enterprises in replacing asbestos fibers with safe fibers for human healthas follows:

•  Construction Minister implements schemes, projects and programs to improve the technology of producing fiber cement roofing sheets.
•  Ministry of Science and Technology support national science and technology tasks on production technology research and use of asbestos fiber substitute materials in fiber cement roofing production;
• • Ministry of Finance researches to issue according to authority or propose policies to support enterprises to invest in new production lines of non-asbestos fiber cement sheets or to convert technology from asbestos cement sheets to a non-asbestos cement sheet; 

4. ​Effect of the project on workers

Comments of the Ha Long Construction Material Co., ltd

"Regarding the content of the proposal. For the Project on " Roadmap stopping using chrysotile to terminating the production of asbestos roofing sheets from 2023"by the Ministry of Construction, the branch of Ha Long Construction Material Co., Ltd proposedthat all proposals in the project on prohibiting or restricting the use of chrysotile should be based on evidence of science, legal and practical, not because of the benefits (from aid) or the impact of some organizations and individuals who had a view to oppose the production and use of asbestos in a hurry to make irrational and inappropriate proposals, to harm the business activities of the enterprise and directly affect the life of workers "

Comments of the Ministry of Construction:

Implementing the direction of the Government’s Prime Minister on the construction of the Project on "Roadmap stopping using chrysotile to terminating the production of asbestos roofing sheets from 2023", the Ministry of Construction has developed a Scheme with a view to manage tightly the use of asbestos, gradually limits and eventually ending the use of asbestos in roofing production to eliminate asbestos-related diseases, protects long-term health of people and reduces the risk of occupational diseases. This view is also consistent with the views of the Ministry of Health and relevant ministries, agencies and localities across the country in protecting human health and compliance in line with the common trend of many countries around the world as well as WHO and ILO in stopping the use of chrysotile. The Ministry of Construction does not because of "resources (from aid) or the impact of some organizations and individuals who have views against the production and use of asbestos" as suggested by Ha Long Construction Material Company Limited.

Due to the need for more time to further clarification of the contents of the Scheme, August 17, 2018, the Ministry of Construction issued the document No. 2052 / BXD-VLXD on adjusting the scheme submission schedule on "Roadmap stopping use of chrysotile to terminating the production of asbestos roofing sheets from 2023 "to the Government’s Prime Minister for permission to adjust the deadline for submission to the project by the end of June 2019.

In the coming time, the Ministry of Construction will continue to strengthen the compliance with the regulations on asbestos use in the Decree 24a / 2016 / ND-CP dated April 5, 2016 of the Government on management of construction materials. For the production of asbestos-cement and co-production of asbestos-cement sheets, the Ministry of Health and the World Health Organization has made clearer the effects of asbestos on human health.

Above are comments of the Ministry of Construction responded to the recommendations of Ha Long Construction Material Company Limited./.