Executive Summary - Review of the Ministry of Labour Documents Pertaining to Holmes Foundry Sarnia, Ontario 1950-1988
Beginning in 1958, the Ministry of Health and the Ministry of Labour conducted a series of inspections at the Holmes facilities in Sarnia, Ontario. This report will examine the role of the Ministries at two of the three Holmes facilities. The Caposite and Holmes Insulation plants will be discussed in this report. The Holmes Foundry will be discussed in a subsequent document.
All three manufacturing plants shared a common location until 1974, when the Caposite plant closed and the Holmes Insulation plant moved to a different location in Sarnia. In 1991 the Holmes Foundry was closed by the Chrysler Corporation, which had purchased the facility from American Motors.
During the sixteen-year period when the government conducted air sampling at Caposite they recorded asbestos "counts (that) were the highest ever encountered by this Branch in any of the plants in Ontario." In fact, the Ministry stated in one of their reports that at least one of their samples was "probably the highest asbestos fibre concentration ever recorded".
In 1958 the Company and the Ministry of Health-that was responsible for health and safety at that time-exchanged letters acknowledging the potential health hazards of asbestos exposure. When the Ministry conducted air samples later that year they found levels that were 28 times over the standard. This would translate into exposures that were as high as 6720 times over our current asbestos legal limit! At the time, however, the government issued no Directions or Orders. The Ministry did not return to this plant for another nine years.
When the government inspectors finally returned in 1967, they estimated the total production at the Caposite plant at 10,000 pounds per day of asbestos insulation. The government inspectors took 345 were below the legal limit then in place. The average sample was 2.7 times the standard of the day. By Ontario's current standards, there were samples that were 1890 times higher than today's legal limit.
The Ministry issued 9 Directions to the Company regarding ventilation and asbestos handling. These Directions were not followed up, nor enforced.
Government inspectors did not return to check the asbestos levels at the Caposite and Holmes Insulation plant until 1972, five years after their previous check for asbestos. By this time they acknowledged that, "three cases of asbestosis (were) reported from this company".
Between 1972 and 1973 the Ministry issued 29 Orders/Directions, in response to exposures that reached as high as 852fibres/c.c., which is 8520 times over the current Ontario limit of 0.1 fibres per cubic centimetre (c.c.) of air.
Finally, in 1973, the Ministry issued an Order to "cease" production at the facilities, only to discover on their follow-up visit that the company had ignored the Order.
In the hundreds of pages of Ministry reports there is not one mention of taking legal action to protect the workers exposed to such deadly levels of asbestos.
Asbestos is one of the best-known and studied workplace carcinogens. It is reviled because of its quality to induce cancer and respiratory disease at relatively low levels of exposure. Although this fact was documented in the medical literature from as early as the 1930s, it was Dr. Irving Selikoff and his colleagues at Mount Sinai Hospital in New York who documented the excess disease caused by asbestos and brought this to the public's attention. Their findings revealed very high rates of cancer, including cancer of the lung, larynx, and gastrointestinal tract. Asbestos was also shown to cause a fibrotic lung disease, called asbestosis.
Mesothelioma, a fatal cancer usually found on the lining of the lung, is specifically recognized in Ontario-as is asbestosis-as arising from exposure to asbestos. Mesothelioma is written into the Compensation Act as a Schedule 4 Disease.
And yet, in spite of the government's awareness about the potential adverse health effects present at the Holmes facilities, the inspectors and technical staff failed to enforce the asbestos regulations. They witnessed and recorded illegal and excessive asbestos measurements that were thousands of times higher than our current exposure limits and hundreds of times higher than was permissible at the time.
In 1987, a Ministry of Labour epidemiologist, Dr. Murray Finkelstein, prepared a study titled Mortality Among Employees of a Sarnia Ontario Factory Which Manufactured Insulation Materials From Amosite Asbestos.
Dr Finkelstein's findings were staggering. He found a six-fold increase in lung cancer mortality among the Holmes workers exposed to asbestos for two years or more. He also documented an eleven-fold increase in respiratory disease mortality and a four-fold excess of all malignancies.
Dr. Finkelstein also cited five cases of mesothelioma among former Holmes workers. Three of the five workers died at less than fifty years of age and all were less than sixty years old!
It is important to remember that the Ontario Royal Commission on Asbestos defined the Johns Manville plant in Scarborough as being a "world-class industrial disaster" due to the asbestos exposure tolerated in that plant. And yet, the information from the Holmes facilities revealed an even more startling picture of asbestos exposure. The asbestos measured in 1973 at Holmes where as high as 852f/cc, while at Manville the highest level record was in the 40f/cc range in 1949.
It is not surprising, therefore, that the lung cancer Standard Mortality Ratio (SMR) was a statistically significant six-fold excess at Holmes, thereby confirming fears that the workers faced excessive exposures and a corresponding cancer risk.
The CAW has since also learned that the Workers Safety and Insurance Board (WSIB) has recognized 51 of 54 claims for occupational disease at Holmes: this represents almost twice as many people who have died of occupational diseases at Holmes as died at the Westray mine disaster.
These cancer deaths due to asbestos exposure could have all been prevented. Had the government and industry representatives acted on the information that they alone had (since the government did not share their findings with the Holmes employees), then almost all of these people would have been spared these diseases.
The Holmes experience raises serious questions about the historical role played by the government in its dealings with Ontario employers. It also reflects the current reality, whereby the Ontario government is tolerating exposures to toxic substances such as metal working fluids, diesel exhaust, electromagnetic fields and benzene at many times their safe levels.
We know today that workers exposed to metal working fluids at levels 10 times below the current legal limit will still bear an excess cancer and respiratory disease risk.
The Holmes experience tells us a great deal about our past, as well as the present. It is also, again, a warning about the consequences of negligence and indifference regarding toxic exposures in the workplace.
In the spring of 1998 the Canadian Auto Workers union (CAW) was approached by the Occupational Health Clinics for Ontario Workers (OHCOW) in Windsor regarding the clinic's concerns about the health of former Holmes Foundry and Insulation workers in Sarnia. Mr. Bob Clarke, the CAW plant chairperson, had approached OHCOW-Windsor regarding the considerable number of workers with cancer, hearing loss and respiratory and heart disease. The Holmes operation had ceased in 1991.
The CAW initiated a process to investigate the potential health problems of former Holmes workers that might be related to their work exposures. This investigation culminated in a public meeting at the Communication, Energy and Paperworkers (CEP) Hall in Sarnia on September 8th, 1998. Numerous unions, OHCOW, the Windsor Occupational Health Information Service (WOHIS) and the Ontario Federation of Labour (OFL) participated in supporting this initiative.
Over 300 former Holmes workers and their families turned out to document their health problems.
As part of its investigation, the CAW requested copies of the Ministry of Labour reports arising from the government's involvement with the former Holmes Foundry and Insulation plants. The CAW was entitled to see these reports through the provisions of the Freedom of Information Act.
What follows here is a summary of the government records regarding the former Holmes Insulation and Caposite plant in Sarnia. There will be a separate report focused specifically on the former Holmes Foundry.
There were three separate operations being conducted in Sarnia at the Holmes facility. First, there was the Holmes Foundry (which will be addressed in a separate report). Second, there was the Caposite Insulation plant. Third was the Holmes Insulation plant. The Caposite plant closed in 1974 and at approximately the same time the Holmes Insulation moved to another location.
Dr. Murray Finkelstein, in his 1985 Ministry of Labour report, summarized the Caposite process:
"In 1956 Caposite Insulations Limited (which was later known as Holmes Insulation Limited, the Insulation Division of Holmes Foundry Limited) began manufacturing insulation products using amosite asbestos imported from South Africa. Caposite was pipe insulation made up of amosite asbestos (55 - 60%), perlite, dicalite, and silicate. During the 1960s, the manufacture of "Uniblock" insulation was begun in the same factory building. Uniblock was compressed rock wool insulation formed from a mixture of rockwool, asbestos. Perlite, and resins. Rockwool insulation materials had been manufactured throughout this period in a separate building on site. Manufacture of asbestos-containing materials was terminated on March 22, 1974. The Company relocated to a new site in Sarnia and was purchased by Babcock-Wilcox."
The Holmes Insulation plant utilized rockwool to produce insulation block.
"The company manufactures insulation mattresses from rockwool. The raw materials - steel - furnaces slag, coke and quartzite stone are molten in a cupola furnace. The molten product is then spun into fibres by pouring it on rotating steel discs. The spun fibres are sucked into a tunnel, pressed by rollers into a blanket and sprayed with a solution of a phenol-formaldehyde resin. The blankets are then dried in a drying oven and conveyed through a tunnel to the curing oven. The cured blankets are, after leaving the curing oven, cut by mechanical saws and stored." (June, 1977 Ministry Report)
What Did the Ministry Know, and When Did They Know It?
According to the Ministry of Labour documents, the management of Caposite Insulation wrote the Minister of Health in 1958 saying:
"From our understanding of asbestos mining, it appears that there is quite a hazard of developing impaired lungs in that occupation."
The Ministry of Health responded with:
" In reference to your letter of April 29th, the breathing of air containing a certain amount of fine asbestos dust may in time cause injury to the lungs. It is considered that the amount of fine fibre dust in the air should be kept below 5 million particles per cubic foot of air."
This correspondence, in which the Ontario government and the employer acknowledged the potential danger of asbestos exposure, was followed up in June 1958 when the Ministry conducted air sampling at the Caposite plant. One of the samples registered 134.4 million of particles per cubic foot (mppcf). By the standard of the day, this represented an exposure almost 28 times the legal limit!
June 10, 1958 Dust Counts Taken at Caposite Insulations Limited
|Operation||Location||Greenberg -Smith (dust counts, millions of particles per cubic foot)||Bausch and Lomb (dust counts, millions of particles per cubic foot)||Translated into fibres/cc|
|.platform Disintegrating machine No. 1 Going||
|15.0, 22.1, 25.3||75, 110.5, 125.15|
|...pipe rolling machine No. 3||
|13.3, 14.9, 24.2.||66.5, 74.5, 121|
|Behind pipe rolling machine No. 3 (west side)||
|Too Dense to Read||672 (based on Greenberg-Smith measurement)|
|..end of automatic saw||
|6.3, 7.6, 8.4||31.5, 38. 42|
|Discharge end of automatic saw||
|11.5, 13.7||57.5, 68.5|
"Standard was 5 million asbestos particles per cubic foot of air"
Using the current Ontario standard of 0.1 fibres per cubic centimetre (f/cc), this exposure would be 6720 times the current allowable exposure limit in Ontario!
At the time, the Ministry issued no orders or directives. The Government, according to its own documents, waited for another nine years before they returned to re-sample at the plant.
1967 (nine years later)
In 1967 the Ministry estimated the total production at the Caposite plant to be 10,000 pounds per day of asbestos insulation. The government inspectors took 34 air samples, of which only 5 were below the legal limit then in place. In spite of these high asbestos exposures, the Ministry issued 9 orders or directives. The average sample was 2.7 times the standard of the day!
February 14, 1967 Dust Counts at Caposite and Uniblock Operations
Million Particles per cubic foot
|Translated into fibres/cc|
|At Asbestos Feed on Mezzanine Floor||6.4,6.5, 14.0,7.3||32, 32.5, 70, 36.5|
|Under mezzanine Floor at Mill operation||23.2, 27.1||116.0, 135.5|
|At Cabinet where milled material dropped||13.5, 12.0, 7.6||67.5, 60, 38|
|Spreader Operation||19.0,18.7, 20.8||95, 93.5, 104|
|At Mandrel during roll-up and facing||13.0, 9.6, 9.9||65, 48, 49.5|
|At small diameter cut-off and splitter-feed end||10.3, 16.1, 9.2||51.5, 80.5, 46|
|At small diameter cut-off, and splitter-feed discharge end||4.4, 6.8, 3.4||22, 34, 17|
|Large Diameter cut-off and splitting||8.2, 6.0, 6.2||41, 30, 31|
|Background at Uniblock mixing||2.4, 1.8, 1.9||12, 9, 9.5|
|Dumping asbestos||6.5, 14.9||32.5, 74.5|
|Dumping Perilite||37.8, 31.9, 36.0||189, 159.5,, 180|
|Dumping Rockwool||19.9, 5.7||99.5, 27.5|
By Ontario's current standards, there were samples that were over 1890 times higher than today's legal limit.
The Ministry issued 9 Directions to the Company with regards to ventilation and asbestos handling. These Directions were not followed up or enforced.
1972: (five years later)
Government inspectors did not return to check the asbestos levels at the Caposite and Holmes Insulation plant until 1972, five years after their previous check for asbestos. By this time they acknowledged that "three cases of asbestosis (were) reported from this company".
On May 17, 1972, the government officials issued directions. Mr. G.S. Rajhans, a Ministry of Health engineer, wrote:
"The handling of amosite asbestos at the feed platform constitutes very serious health hazards. This is also reflected by the air samples taken during the visit. The first sample was taken when the fibres were being broken by means of a pitchfork. This sample is 33 times the determined TLV. As a matter of fact, the writer has not seen such an excessive asbestos exposure anywhere else. The men engaged in breaking the fibres (were) practically covered with the loose fibres. An approved type respirator is provided to this man. However, it is my contention that this respirator would not prove to be very effective in such an excessive asbestos exposure. In fact, I would not be surprised if the man develops asbestosis before too long. The only respirator which could prove to be of some help would be an air line respirator. Mr. Burton has already issued a direction for such a respirator.
A considerable amount of dust is also produced at the disintegrators. The sampling found levels as high as 24 times the TLV. Thus, there is a need for adequate local mechanical exhaust for the disintegrator." (Our emphasis)
The May 17th visit was followed up on May 30th. Once again the Ministry issued six (6) orders regarding the exposures to asbestos. The Company had still not complied.
On August 31, 1972 the Ministry returned again. This time Mr. L. Bithel, another Ministry engineer, made another Field Visit. He wrote:
"This visit was made to assess compliance in the completion of directions issued following the last visit. Three of the six directions have been adequately complied with, but no progress has been made on the remaining three, which concern the most serious exposures in the plant. These directions are still valid and are repeated with a time limit. One additional direction is suggested.
In the disintegrator area (15ft x 12ft) there was a lot of visible asbestos dust.
Conditions at the feed platform and at the disintegrators are poor. The dust was quite visible in the disintegrator area, and it could be seen spreading to other areas, moving just below the ceiling.
Three of the six directions have been adequately complied with (directions 81, 82 and 85). However, the remaining directions cover the most important sources of asbestos dust emissions, and it is essential that they be carried out."
The Ministry issued 4 directions; three were repeated from the last visit.
The government inspectors did not return again to Holmes Insulation for another four months. On January 29, 1973, Mr. Nelson wrote another report with suggestions for more directions. He also reported on Ministry sampling, which found very high fibre counts that were hundreds of times in excess of the legal limit.
January 15, 1973 Air Sampling for Asbestos Fibres on Caposite Line (>5 microns in length per cc air)
No. and Location
|Asbestos Fibres (>5 microns in length/cc)|
|1. Inside the disintegrator Enclosure||852|
|2. disintegrator Feed hopper, Mezzanine Floor, beside the Operator||640|
|3. Outside the disintegrator Enclosure, between Rolling Machines 2 and 3 (feed end)||243|
|4. Between Rolling Machines 1 and 2, at the Rolling End||1.8|
|5. Automatic trimming saw, feed end||7.9|
|6. Automatic Trimming Saw, discharge end and Packaging||35.3|
|7. Large "Band" Saw (Cutting and Packaging)||5.4|
|8. Background, in aisle beside the office, between the Caposite line and the uni-block machine||1.0|
January 15, 1973 Air Sampling for Asbestos Fibres on Uni-Block Line (>5 microns in length per cc air)
|9. Discharge End of Uni-block Machine and Packaging||2.1|
|10. Mixing Platform of Uni-Block Machine (charging Large Mixer)||10.1|
"The present TLV for asbestos fibres is 2 fibres greater than 5 microns in length per cc. of air. Six of the Samples were above this Limit."
By today's asbestos standards, one of these measurements would have registered 8520 times over the legal limit!
The January 29th Field report stated:
"The above mentioned company (Holmes Insulation) has been visited several times in the past. Mr. L. Bithel visited last in August 1972. He suggested re-issuing of directions with a four- month time limit. The writer was of the opinion directions had not been adequately complied with. Subsequent air sampling indicated conditions had seriously declined with very high asbestos fibres in air. (Our emphasis)
This report will suggest that action should be taken to halt all operations involving asbestos.
At the above-mentioned company, air sampling was first done in June 1958. Dust counts ranged from 2.1 to 134.4 million particles per cubic foot (mppcf). In February 1967 the writer did a ventilation and dust survey showing counts to 27 mppcf in asbestos handling areas. At that time 7 directions involving ventilation of asbestos operations were suggested. In April 1972 Mr. Rajhans visited the plant and suggested 6 directions. Mr. Bithel visited in August 1972 and suggested re-issuing three of Mr. Rajhans directions plus a fourth direction. He suggested these be issued with a four-month time limit.
Considerable dust was noted leaking from around the disintegrator and fluffer machines, as well as at the wet roll up operations. The only difference noted in this visit from what was described in previous reports was a polyethylene curtain hung to segregate the disintegrator from the rest of the plant. A slight inflow of air was noted into the curtained off section. The operator on the mezzanine floor feeding the disintegrators was wearing an air-supplied helmet. An operator who may work within a few feet of this man is not required to wear a helmet.
At the time of the 1958 and 1967 dust surveys the Threshold Limit Value in effect was 5 mppcf. Results recorded were generally above this figure and directions were suggested.
On January 15th (1973), following this visit, fibre counts were done by our laboratory. Results ranged from 1 - 852 fibres greater than 5 microns per cubic centimetre (fibres/c.c.). The figure of 852 is probably the highest asbestos fibre concentration ever recorded. (Our emphasis) The high figure was in the disintegrator enclosure. While the enclosure may not be considered a normal work area, counts of 243 and 640 fibres/c.c. were measured in two work areas. On 10 counts, only 2 were below the TLV of 2 fibres/c.c. with one more below 5 fibres/c.c.
These figures can only be considered as alarming.
There has been no indication of progress in controlling asbestos at this plant. In fact, it would seem that the systems are deteriorating rapidly. All asbestos operations are scheduled to stop in about 6 months. It is my opinion the level of exposure is too high to possibly consider permitting it for a further six months.
It is suggested a direction be written requiring the company to cease all operations involving asbestos immediately."
In spite of the fact that the Ministry has just documented, "the highest asbestos fibre concentration ever recorded" and indicated that the Ministry issue a directive to "cease" operations, the government did not enforce this order and simply continued to re-issue 'old' directions.
A few days later, Dr. E. Mastromatteo, Director, Environmental Health Service, wrote to Dr. G.K. Martin, a Ministry of Health official, to warn, "recent developments (at Holmes Insulation) may raise questions which may be drawn to the attention of senior officials of this Ministry." After describing asbestos exposure that he characterized as "very high", he concluded with:
"You should also know that the asbestos used in this plant has been traced by The New Yorker Magazine from a plant in Port Tyler, Texas. The Texas plant was also engaged in the manufacture of high-temperature asbestos insulation products. It ceased operations following studies by the U.S. National Institute of Occupational Safety and Health (in HEW). High levels of asbestos in air and many workers with asbestosis were found."
On February 16th, Mr. Rajhans returned to inspect Holmes Insulation and to determine whether the directions were being followed. He wrote:
"This visit was a follow up of the one made in January 1973 by Mr. Nelson.
Mr. Nelson suggested that all operations involving asbestos should be ceased, until the level of asbestos contaminants is brought down within the present allowable TLV of 2 fibres per cubic centimetre. As a result, the "Caposite" line was shut down by the Industrial Safety branch. However, the company has now resumed the operation.
This report would indicate that no basic improvement in controlling the asbestos exposure at this plant has been made. Results of air sampling done on February 13, 1973 following this visit, also indicate that the condition is as alarming as before. It is, therefore, suggested in this report that the direction suggested by Mr. Nelson to halt all operations involving asbestos should still apply.
The above mentioned company has been visited several times in the past by the writer, Mr. H. Nelson, and Mr. L. Bithel. The plant and operations have been described in detail in the earlier reports. In all the previous reports several directions were suggested to reduce the asbestos exposure to a minimum. It was found during this visit that none of the directions were complied with.
As mentioned earlier, no basic improvement has been made in the dust, and ventilation conditions of the plant. This is also reflected in the results of air sampling done on February 13th following this visit.
The fibre counts range from 4.7 fibres per cc, to 837 fibres per cc, which are basically the same as found on the previous visit, when the results ranged from 1 - 852 fibres per cc. The two counts which were found to be below the TLV at the previous occasion are now above the TLV.
Thus, it should not be difficult to realize from these counts that the level of asbestos exposures is still too high to allow it to continue for any length of time.
In my opinion, it is almost impossible for the company to reduce the asbestos exposure by a considerable amount unless all operations involving asbestos are completely mechanized, totally enclosed, and adequately exhausted. Any attempt to resume the operations without providing adequate control measures should be discouraged.
It is obvious from the above mentioned comments and air sampling results that the two directions issued by Mr. R. Halliday, and suggested by Mr. H. Nelson in his report dated January 29, 1973, have not been complied with. Hence, it is suggested that the two directions should be rewritten and all operations involving asbestos be halted."
Two weeks later, on March 7th, the Ministry returned to the plant. This time Mr. Nelson wrote that there had been some improvement, but qualified his remarks with the following comments:
"Improvement" is a relative word and in this case should not be construed as indicating an acceptable condition. No count is below 2 fibres per cubic centimetre and there is still one count over 100 fibres per cubic centimetre. The average of all counts is 19.5 fibres per cubic centimetres.
Normally these results would be unacceptable, but since the Company are phasing out all operations involving asbestos I would recommend the Company be permitted to carry out the operation for a period not to exceed five (5) months on the following conditions." (This notion refers to sampling carried out on March 6th, 1973.)
The Ministry conducted its last asbestos sampling at the Caposite facility on May 1, 1973. After sampling for asbestos for fifteen years, after documenting at this facility the highest asbestos exposures ever recorded in Ontario, after issuing 38 directions and orders to the company, the government recorded five samples out of eight over the legal limit of 2 fibres/c.c.
In February 1975 the Ministry Dust Specialist, Mr. Rajhans, prepared a history of this period. What follows below is a summary of how the Ministry viewed itself at the Holmes Insulation/Caposite operation:
"Our records show that the plant started working in 1956 and on April 29, 1958 a letter was received from Mr. Allan, Personnel Officer on the plant to indicate that they are concerned about the asbestos hazard, and they are asked us to X-ray the employees.
(Mr. Walls) also indicated in his report that the plant was considered very dusty in his opinion. The TLV as far as I remember at that time was 5 mppcf. So in other words, the counts were much above the TLV. We have no records of any visit between 1958 and 1967. Mr. Nelson visited the plant in 1967 and wrote a detailed report and suggested a total of 9 directions including adequate ventilation on various equipment and adequate housekeeping. He also indicated in his conclusions that the conditions are undesirable and directions should be complied with to improve conditions.
Mr. G.S. Rajhans made a visit on April 25, 1972. In his detailed report regarding various parts of the plant, he mentioned that the conditions were deplorable and immediate action was needed by the Ministry of Labour to improve the conditions. As a result, he suggested 6 directions and one of his comments was that he had not seen anything like this or any conditions as bad as the plant showed.
In January 1973 Mr. Nelson investigated a compensation claim of an employee by the name ...... who had contracted some kind of lung disease close to asbestosis and Dr. J. E. Cowle of the Industrial Chest Disease Section wanted to know what his exposure was. An extensive air sampling survey was done in the plant on January 15, 1973. The results indicated dust counts much more in excess of the TLV. Fibre counts were the highest ever encountered by this Branch in any of the plants in Ontario. Some of these counts were a hundred times or more than the TLV.
In January 1973 Mr. Nelson followed up Mr. Bithel's visit of August 1972 and the report dated January 29, 1973 shows that the company had not complied with the directions and even the time limit, they had not paid any attention to. In his report Mr. Nelson indicated that all asbestos operations should be stopped unless the counts were brought down below the TLV of 2 fibres per cc. On February 9, 1973 Mr. Rajhans further followed up Mr. Nelson's visit of January 1973 and agreed with Mr. Nelson that the plant had not been able to bring the counts below the prescribed limit, and as a result he suggested that Cap line, which was the dustiest operation in the plant, be shut down. Consequently the Industrial Safety Branch shut down the Cap line.
Mr. Rajhans' visit was then followed up by Mr. S. Morton of the Occupational Health Laboratory to check the fibre counts again and see if they had been brought down. His report indicated all samples were above the limit by as much as 200 times.
On March 7, 1973 Mr. Nelson wrote a memorandum to the Ministry of Labour asking them to be very strict with the company and he recommended that the company be permitted to carry out the operation for a period not to exceed 5 months on the following conditions.
A further memorandum was written by Mr. Nelson indicating that we have not been as strict as we should be and repeated what he said in his earlier memorandum, i.e., that the sampling be done and if the results are high, the plant should be shut down. Following Mr. Nelson's memorandum a visit was made and air sampling was done by the Occupational Health Laboratory on April 26, 1973, with the results documented in a report dated May 1, 1973. The results indicated much lower counts than previously encountered, however 4 of the 8 counts were still above the TLV."
In spite of the assertion by the Ministry of Labour that they closed down the asbestos operation, the government, in fact, only issued one such order (January 31, 1973). This order was not enforced, nor complied with by the Company.
At no time did the government take legal action on behalf of the Holmes workers to enforce their orders.
Dr. Murray Finkelstein, a Ministry of Labour epidemiologist, prepared a report to access the "Mortality among Employees of a Sarnia Ontario Factory which Manufactured Insulation Materials from Amosite Asbestos" in 1987. This report came almost thirty years after the government first registered high asbestos fibre counts at the plant. Dr Finkelstein documented mortality rates that were far in excess of the general population:
"Insulation materials were manufactured at Holmes Insulations Limited in Sarnia, Ontario using amosite asbestos from 1956 - 1974. Using primarily a list compiled by the Occupational Chest Disease Service of the Ministry of Labour, a roll of 152 former employees was assembled and the mortality experience of the workers was traced. Among the 108 men who could be identified as having worked in asbestos exposure, there was a 6-fold increase in lung cancer mortality (4 deaths observed; 0.66 expected), a 7-fold increase in respiratory disease mortality (3 deaths observed; 0.42 expected), and there were 2 deaths from mesothelioma. A third death from mesothelioma has occurred since the close of follow-up for this study, and 2 additional deaths from mesothelioma are known to have occurred among former Holmes workers not on our roll. Three of the 5 men dying of mesothelioma were less than 50 years of age at death and all were less than 60 years.
The 152 former workers we could identify and place on the study roll are only a subset of employees who worked with asbestos at the factory."
As an almost ironic note, the Ministry wrote in August of 1973 "there is no safety programme at Holmes Insulation."
In March 1974 the Caposite facility was closed and the Holmes Insulation operation moved from Scott Road to North Christiana Street in Sarnia. Babcock & Wilcock Ltd purchased the Company. According to Ministry records (December 6th, 1974 memo) the Company was, "engaged in the manufacture of high temperature insulation products. Mineral wool has been substituted for asbestos. No asbestos is used in the new plant."
The Ministry indicated, however, that in the old building:
"There is likely to be a considerable amount of asbestos dust in the fabric of the building and on the steelwork."
The Ministry memo stated that the Company employs 110 people. Holmes Foundry, a subsidiary of American Motors, has purchased the old Holmes Insulation building. This facility will serve as a "storage depot" for the Foundry.
In the Ministry's last memorandum of 1974 (December 24th, 1974) Mr. Chappel, Legal Branch, stated that Holmes Insulation was found "guilty" and fined $500 on each of two counts resulting from an accident.
On January 10th, 1975 the Ministry of Labour held a Management Safety Consultation with Holmes Insulation management. The Company expressed "bitterness" and informed the Ministry that it intended to appeal their recent conviction.
The Ministry made the following observations:
"The Company does not have an organized safety programme, no printed safety rules or a safety committee.
He (Mr. Bechard) also informed me that a concentrated drive was made in July 1974 to have all machinery guarded where any possible hazard might exist. It would appear that such effort was short lived, as indicated in the inspection report of September 26, 1974 when six (6) machine operations were listed as unguarded.
It is my opinion that my (management) contact is more concerned with production than safety of the workers; his attitude may change."
In 1974 the Ministry issued 19 Directions/Orders. Nine (47%) were related to "guarding and guardrails".
On January 24th the Ministry of Health Protection Branch visited the Holmes Insulation facility in response to four persons being "affected" by carbon monoxide.
"On December 9, 1974 4 persons were affected in the area of the large cupola in this plant, which manufactures rockwool insulation. The cause of the trouble was apparently an escape of carbon monoxide due to backdraughting from the stack. One man went home with nausea.
At the time of the visit, only the small cupola was operating. Sulphur dioxide could be detected at the top level, and blue fumes were observed coming from the top of the cupola.
Because of the very high carbon monoxide concentrations which may be present in the cupola gases emitted into the air, operators should be warned of the danger, should avoid the obvious leaks and should spend a minimum time in the top level, until the problem is solved.
In our experience, the cupola off-gases can contain up to about 5% carbon monoxide, or 50,000 parts per million, so it is evident that strict precautions are required to ensure that the carbon monoxide level is kept at a very low level."
The legal limit for carbon monoxide at that time was 50 parts per million. The short-term limit was 400 parts per million for 15 minutes. The Ministry cited potential exposures that were 1000 times the legal limit!
On February 11th Mr. Rajhans prepared a memorandum that summarized the Ministry's experience at Holmes Insulation:
"Our records show that the plant started working in 1956 and on April 29, 1958 a letter was received from Mr. Allan, Personnel Officer on the plant to indicate that they are concerned about the asbestos hazard, and they are asked us to X-ray the employees."
A Mr. Hesch, from the Ministry of Labour "received a complaint from the wife of a worker about fumes and smoke."
On May 5th the Sarnia Observer reported that:
"The company was charged with failing to ensure that proper safety requirements were maintained. An employee, Clifford Missard, received severe arm injuries after his shirt was caught on a chain sprocket of a pipe machine drive in the plant."
The company was found guilty and fined $1000.
In 1975 the Ministry wrote 36 Directions/Orders. Twenty-five (69%) were for "guarding and guardrails".
In 1976 the Ministry made three visits to Holmes Insulation. They issued 7 Directions/Orders, 4 of them for "guarding and guardrails".
On February 16, March 7th and March 23rd the Ministry visited the plant due to complaints about heavy smoke in the facility.
"Request inspection of the above firm (Holmes Insulation) due to a heavy smoke problem caused by a negative pressure is hazardous to health, conditions are bad." Mr. Halliday
For the first and only time the Ministry documents contained a request from the Chief Medical officer of Sarnia.
"Dear Dr. Fitch, I have had a complaint about high smoke levels inside the plant. I would be grateful if you could arrange for an inspection. While it is true that this Company has spent much money in recent years on pollution control, I do feel you should investigate this complaint. Yours sincerely, Lucy Duncan, M.B., D.P.H., Director and Medical Officer of Health"
During Ministry visits in June, July, September, and December the focus was on the "heavy" smoke in the Insulation plant. The Ministry stated that:
"Although the indicated concentrations of phenol and formaldehyde were within the accepted T.W.A., their concentrations may easily rise when the negative pressure in the working area is increased (e.g. when doors are closed)."
The Company plant engineer, Mr. Doug Cole, ended the year with a memo to the Ministry, which stated:
"It was, however, established that the conditions could worsen in winter months and that long exposure to the smoke could irritate existing conditions such as bronchitis or similar health defects."
Mineral wool, carbon monoxide, phenol and formaldehyde were the toxic substances that became the focus of the Ministry's May 24 visit. The inspectors discovered that:
"The personal sample of the loader of the Uniblock machine indicated 59.6 mg/m3 of air of rock wool dust. This is almost 6 times the TWA for inert dust accepted in the Province of Ontario (10 mg/m3 of air)."
In a separate visit two weeks later, the Ministry again found "Mineral Wool dusts in excess of allowable Ontario standards at the charging deck of the Uniblock machine."
In July the Ministry wrote in an "internal memo" that from June 22, 1977 until June 6, 1978 (12 months) the Ministry of Labour issued 11 Directions regarding Ventilation, 7 were repeat Directions.
The memo continued with an assessment that said:
"There is no safety program of any type when a new employee steps in the plant. He is given a book of rules and regulations, told to read it and he is then turned over to a foreman on a labour gang.
There seems to be no supervision to advise employees to replace guards, work in a safe manner, as this last report points out by the number of directions issued on unsafe conditions where A-10s had to be issued."
The memo concluded with "I (Mr. Burton) feel this plant and management are very fortunate in not having more accidents under the present working conditions."
The Ministry notes that, "the union has just been changed to the U.A.W."
On October 30, 1978 the Ministry conducted sampling to determine the noise levels with the Holmes Insulation plant.
"A noise survey was carried out at the above-mentioned plant (Holmes Insulation). The attached survey form indicates that several employees in the spinner area are exposed to noise in excess of the criteria outlined in Section 111, Ont. Reg. 259/72 of the Industrial Safety Act, 1971."
The noise levels recorded by the Ministry of Labour are listed below:
October 12, 1978 Sampling for Noise Levels
|Location - Operation||Exposure Profile||DB (A)|
|Charge make up area, general Slag, coke, stone loading||Cont.||86 - 88|
90 - 98
|Cupola area, general||Cont.||91 - 94|
|Flat line, at the machine||Cont.||93 - 95|
|Flat line, at the tanks||Cont.||88 - 90|
|Flat line, in the booth, provided for the operator||Cont.||74 - 76|
|R. Max line; at the machine||Cont.||100 - 102|
|R. Max line; at the operator's desk||Cont.||91 - 93|
Of the eight samples, only two were below the TLV of 90 dbs.
In 1978 the Ministry of Labour issued fifty-six Orders/Directions, seventeen (30%) of which were for "guards and/or guardrails". Six Orders were repeated, while other Orders were issued regarding noise levels and rockwool exposures over the legal limit.
In an October 1979 Ministry of Labour Update, Mr. Burton stated that:
"This company has been traditionally reluctant to make positive moves to maintain a safe workplace."
Mr. Burton essentially repeated the continued Ministry perspective:
"There is no evidence of any improvement in the operation of this firm although I have been informed the mew Manager contemplates changes towards better Health & Safety matters. Presently there is no safety program and there seems to be no drive from Management to make better working conditions or control to replace guards when repairs are done."
In 1979 the Ministry issued fifteen Orders, eleven (73%) of which were for "Guards and/or Guardrails".
The UAW presence had an impact on the health and safety conditions.
"There has been a significant change in the plant in general since my last inspection. A new union (UAW) has been formed. The management, with the union, has formed a health and safety committee with internal audits monthly. The audit report is posted and action is being taken to correct problems. There has been no directions or recommendations issued on this inspection."
The Ministry also acknowledged that asbestos disease was being documented and compensated:
"Compensation for asbestos related disease has been awarded against this company but the Industrial Health and Safety branch's file did not reflect an asbestos evaluation at this plant."
The Ministry took noise measurements that, once again, were significantly above the legal standard.
October 20, 1981, Sampling for Noise Levels
|Location - Operation||Exposure Profile||DB (A)|
|Preform Pipe Cutter||Continous||102- 104|
|Preform Pipe Cutter Operators Work Station||Cont.||101 - 103|
|Adjacent Work Station 10' Away||Cont.||84 - 86|
|Adjacent Work Station 15' Away||Cont.||83 - 85|
Holmes Insulation informed the Ministry that the composition of the Mineral Wool was 46-48% silica by weight.
1982 - 1986
The Ministry of Labour issued fifty-six Orders/Directions between 1982 and 1986. It conducted no inspections during 1985. Twenty-nine per cent of the Orders were for "Guards and Guardrails".
During this period the Ministry expressed concern about potential silica exposure. There was also a "critical injury" reported in June 1986.
Dr. Murray Finkelstein conducted a study to determine the extent of the health problems found among the former Caposite workers.
The following table was in his report:
Table 7: Mortality Among Workers Exposed to Asbestos for 2 years or more (Finkelstein, 1985)
|Cause of Death||Observed||Expected||SMR||p-value|
Dr. Finkelstein further stated:
"The men who died of mesothelioma were 47 and 49 years of age at death; the intervals from first exposure were 26 and 21 years respectively. After the end of the follow-up period for this study, a third man in this group of 55 died of peritoneal mesothelioma in May, 1986. He was 50 years old when he died, 27 years after first employment. In addition to these 3 men, 2 other Holmes employees have received Compensation awards for mesothelioma. The names of these men do not appear on any list available to us when the cohort was assembled. Both of these men began work in the mid-1950s. One died in April 1987, at the age of 59, of pleural mesothelioma. The other man died in 1982, at the age of 42, of peritoneal mesothelioma." (p. 13)
In the report, Dr Finkelstein recorded the comments of a Dr. Ritchie:
"Professor A.C. Ritchie, the Consultant in Pathology to the Workers Compensation Board, reviewed the slides from the autopsy (a man who died of lung cancer at the age of 49). He found numerous asbestos bodies in the lung tissue and commented, "I have never seen a case in which contamination by asbestos is so great." With respect to a 54-year-old man who died of asbestosis, Dr. Ritchie reported finding severe asbestosis. This man had worked for 8 years as a pipe roller.
Two of the 10 deaths were from causes not usually attributed to asbestos exposure, namely kidney cancer and heart attack. For the man who died of a heart attack, Dr. Ritchie reported severe asbestosis."
In 1987 there was also a "critical injury" involving a worker who became unconscious after being poisoned by sulphur dioxide.
1988 - 1991
From 1988 to 1991, when the Ministry made its last inspection, there were 11 Orders issued, all in 1988. These Orders were in response to another amputation due to the guard having been removed.
There is also mention of medical monitoring of workers exposed to silica. Noise and carbon monoxide exposures are also mentioned.
During the thirty-three years that the government officials conducted inspections and other activities at Caposite and Holmes Insulation, 275 Orders/Directions were issued, of which 34 per cent were for "guarding and guardrails".
The government records noted that they measured the "highest levels of asbestos recorded" while sampling at the asbestos insulation plant in Sarnia.
During the fifteen years that the government sampled for asbestos, it issued only one Order to stop production. This Order was ignored and forgiven.
The Ministry sought Legal Action only once, in 1975, as a result of a "critical injury" during which a worker lost a finger. The Company was fined $1000.