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response
relationship, which in turn is used to determine acceptable levels of
exposure. Successful intervention to reduce the burden of disease attributable to
work will depend on the accurate identification of risk, not only by agent but by task
and by location.
4.4.3 All the evidence presented to the Commission supports the view that urgent action is
required to upgrade the standards of practice in respect of the measurement of
workplace exposures, medical surveillance and the matching of these two data sets,
and the COMMISSION RECOMMENDS accordingly. Only in this way can the
workplaces which actually lead to disease in workers be identified and targeted for
remedial action.
4.4.4 A safe working environment will remain a goal which cannot be reached so long as
the fundamentals of occupational health are not
more widely understood than
appears to be the case at present. Evidence submitted to the Commission established
clearly the central role of the process of risk assessment. This process must begin
with the establishment of an expert occupational health programme provided at or
near work places. This is prescribed in terms of the OHS Act by Section 8(2) (d)
which will be dealt with in the Commission’s Recommendations.
4.5
TRENDS IN OCCUPATIONAL DISEASE INCIDENCE OR PREVALENCE
4.5.1 All witnesses agreed (either implicitly or explicitly) that there are considerable
difficulties in determining trends. As was stated elsewhere these difficulties include
uncertainties in respect of both the numerators and the denominators used in making
the calculations. Numerators are unreliable as a result of widespread under
ascertainment, due, inter alia to defects in medical surveillance, under reporting, the
migrant labour system and the characteristic long lag
period of many occupational
diseases. Denominator difficulties arise from the use of global figures for the
number of workers employed and the difficulty in establishing the size of particular
risk groups, such as stope workers, accurately. In many calculations data from
mines of widely differing depth and geographical location are aggregated, and in the
case of minerals other than gold, platinum and coal, a wide spectrum of mines
producing anything from andalusite to zinc are treated as a single group.
4.5.2 A further complication is introduced by the division,
in terms of the ODMW Act, of
mines into those which are controlled and those which are not, and by the separation
of those mines which are owned by companies which are members of the COM into
a separate group, and a proportion of mines do not report at all. Meaningful
discussion of the health risks and the health trends in the mining industry will be
difficult, if not impossible, until all mines are grouped by process and valid
measurements made of the environmental conditions in all mines.
4.5.3 The detailed evidence submitted to the Commission in writing and orally,
approaches the problem in a systematic manner. No evidence was submitted to
suggest that occupational diseases had been adequately controlled
by the industry as
a result of the existing regulatory system. The written submissions of Drs. White
and Leger, supplemented by those of the Work Place Information Group and the
Industrial Health Research Group, enabled the Commission to appreciate the nature
and scope of the health problems in the industry.
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4.5.4 Dr. White, a specialist in the field of lung disease, in a submission running to more
than 120 pages, citing 134 references to mainly South African scientific studies,
demonstrated that those response relationships have been established in South Africa
and elsewhere for exposure to quartz and subsequent silicosis, for exposure to
asbestos fibre and subsequent non-malignant and malignant asbestos related
diseases, for length of mining experience or quartz
exposure and pulmonary
tuberculosis, and for exposure to mine air and chronic obstructive pulmonary
disease. A number of other diseases are also known to be associated with work in
mines. It has also been shown that severity of disease and life expectancy are
negatively correlated.
4.5.5 In determining the trends in incidence there are, it is agreed by White, Leger and
others, formidable difficulties in establishing reliable numerators and denominators,
as discussed above, and in piecing together fragments of information held by the
various agencies involved, viz. the DMEA, the DoH, the Workmen’s
Compensation
Commissioner, the Rand Mutual Insurance Company, individual mines or mining
conglomerates, etc. On balance it appears that there is no conclusive evidence of a
downward trend in the incidence or prevalence of any of the diseases of major
concern in the mining industry.
4.5.6 More importantly the evidence suggests that in almost all instances there is evidence
of under ascertainment of the number of cases, and that stabilisation of the
workforce is likely to increase the incidence and the prevalence of occupational
diseases among the smaller number of persons now employed in mines. Leger (pp
73-77) concludes that as occupational diseases are related to prolonged exposure in
the work environment, increased length of exposure
on its own will result in an
increased incidence of disease. However at least two other factors are likely to
contribute to what may prove to be a very significant increase in the incidence of
pneumoconiosis, noise induced hearing loss and tuberculosis. Prior to stabilisation
workers commonly left the industry before the disease became manifest, but as an
increasing proportion remain in employment for 20 years or more they will develop
the disease while still within range of diagnostic services. The position will be
compounded in respect of pulmonary disease by the fact that older workers are more
susceptible to tuberculosis.
Leger then cites evidence from a number of sources to show that, despite the fact
that “No direct measures of mine service or the age profile
of the workforce as a
whole exists”, the demographic change is surprisingly rapid. A series of studies of
autopsy data shows that in 1988 58% of miners dying in service were between 20
and 29 years of age, but by 1992 the comparable figure was 19%.
4.5.7 Solutions to the problem depend on “the replacement of the pre-1993 system of
medical intervention with one that is equitable and not racially discriminatory,
effective in both the prevention and early detection of work related diseases,
accessible and affordable, participatory and non-coercive and in addition to adequate
compensation, also offers retraining or alternative placement options to miners with
work related diseases” (White, p 78). It is also evident that much of the information
has been held in confidence by management and that access to mines for research
purposes has not been easy to obtain. There is some evidence
that as a result of the
Commission’s deliberations this will change.