Contents


    Executive Summary

    Asbestos is a highly versatile, abundant, and naturally occurring mineral that has been used in thousands of products of all sorts for more than 100 years. The material consists of natural silicate that is both heat and fire resistant. The basic mineral structure consists of long, thin fibers that can be broken down to add strength and flexibility to nearly any product, allowing asbestos-containing products to be flexible yet strong at the same time without adding excessive weight. It is one of the few minerals that can be woven. Because of this characteristic it was commonly woven into insulating materials to make the products flexible, durable, and unaffected by heat. Because of its impressive qualities, asbestos was often used in the construction of schools, hospitals, shipyards, homes and businesses alike. Asbestos was also widely used in vinyl floor tiles, adhesives, duct insulation for climate control systems, various roofing products, thermal seals, and fireproofing spray.

    It ultimately became evident that asbestos was hazardous to humans, and litigation against companies that made or installed asbestos began in earnest in the 1970s.

    Background

    Plaintiffs’ attorneys bringing asbestos injury claims would name dozens of companies as defendants because plaintiffs could not determine precisely which involved company was responsible for the exposure to asbestos. Attorneys set up mass screenings to attract plaintiffs. Defendant companies sought defense and indemnification from their insurers for these claims. In the mid-1980s, a number of major asbestos defendants entered into an agreement with insurers, “The Wellington Agreement,” in an attempt to resolve asbestos claims outside of the tort system. The Wellington Agreement called for the defendants and their insurers to pay a share of each claim regardless of whether the claim was, or could have been, asserted against the specific defendant being asked to contribute. Some companies, such as Johns-Manville, set up trusts to fund asbestos claims settlements.

    The number of claims and the dollar amounts of the verdicts and settlements caused many large asbestos-related companies to go bankrupt. Plaintiffs’ attorneys began targeting smaller companies that were less directly linked to asbestos, such as companies that used asbestos or sold products that contained minor amounts of asbestos rather than manufacturing it. Eventually hundreds of thousands of people filed asbestos-related claims.

    Injuries and Damages

    Asbestos is not dangerous when it is encapsulated or undisturbed, however, when products containing asbestos are moved or damaged, asbestos fibers are released into the air and can be inhaled or ingested. Asbestos is most dangerous when it is friable, meaning easily crumbled by hand. As a result of the abundant use of asbestos in a variety of products and industries, those who work around the material -- firemen, mechanics, demolition workers, and construction workers -- are at the highest risk of inhaling asbestos and developing asbestos-related diseases. Those directly exposed through their occupations are not the only individuals at risk; people who come into physical contact with exposed workers are also at risk of developing asbestos-related diseases, because particles of asbestos can be carried on skin, hair, shoes and clothing -- and once airborne, the particles can be inhaled by anyone in the direct vicinity.

    When inhaled, the microscopic asbestos fibers embed themselves in the lungs. At this point the body’s natural defense system attempts to break down and remove the fibers. However, because of the extreme resiliency of the asbestos fibers, not all of them can be removed during the body’s attempted cleansing process and the remaining asbestos fibers can irritate lung tissue. If asbestos fibers make their way to the air sacs in the lungs where the exchange of oxygen and carbon dioxide takes place they can cause irritation and scarring and may result in a respiratory disease called “asbestosis”. Asbestos fibers that pass through the air sacs and into the pleural mesothelium (the pleura is the thin layer of tissue surrounding the lungs) can lead to lung cancer and mesothelioma.

    Ingesting asbestos fibers can cause the same types of illnesses in the digestive tract. For example, when someone is exposed to airborne asbestos, some of those fibers become lodged in the interior of the mouth where the fibers are mixed with saliva. Once the exposed person swallows the saliva, the asbestos fibers are carried into the stomach and intestinal tract and eventually move into the abdomen, causing irritation similar to that which occurs when the fibers become trapped in the lungs. There is a latency period of up to 40 years for some asbestos-related illnesses. Asbestos-related diseases are expected to appear in the population at least through 2050 in the United States.

    Legislation and Regulation

    Attempts to regulate asbestos began in the 1970s and continue:

    1973: The Environmental Protection Administration (EPA) prohibited the spray surface application of asbestos-containing insulating or fireproofing materials.

    1975: The EPA disallowed the installation of asbestos pipe insulation and asbestos block insulation on items such as boilers if the insulating materials were friable or became friable after drying.

    1977: The Consumer Product Safety Commission prohibited asbestos in artificial fireplace embers and wall-patching materials.

    1978: The EPA expanded its ban on spray-applied surfacing materials to include materials used for purposes not already banned.

    1989: The EPA banned most asbestos-containing products.

    1991: The rule banning most asbestos applications was vacated by the Fifth Circuit Court of Appeals, effectively overturning most of the original ban on the manufacture, importation, processing, or distribution in commerce for the majority of the asbestos-containing products originally covered in the 1989 ban. New uses of asbestos were banned, however, and use of asbestos in the U.S. declined.

    2016: The Toxic Substances Control Act is amended to require the agency to regularly re-evaluate the harmfulness of toxic materials.

    2018: In August 2018, a measure was passed that mandates EPA review of applications for using asbestos in consumer products. While most developed countries ban asbestos, the U.S. allows its limited use in products such as roofing materials. The new rule is controversial, with some experts stating that it allows for the greater use of asbestos, asserting that the rule would allow some businesses to start using asbestos without government review. The EPA’s acting administrator, however, stated that the plan restricts asbestos manufacturing and processing of new applications for asbestos. The new E.P.A. proposal is a “significant new-use rule” setting out guidelines for what types of asbestos the government considers worthy of an evaluation and the imposition of possible restrictions. The rule does not require that all uses of asbestos be presented to the EPA for a risk review, rather, only 15 specific uses would trigger a federal assessment. The 15-item list includes some common uses for asbestos. Critics contend that the limits would result in other potential uses avoiding examination because the EPA could not anticipate all future uses of asbestos and some uses would likely take place without being weighed for safety risks.

    Liability and Insurance

    Asbestos exposure generates significant insurance issues. Coverage litigation commonly includes disputes over trigger of coverage, number of occurrences, and allocation. Most courts held that a continuous trigger was applicable to asbestos claims, implicating many years of coverage from the date of first exposure to the date of manifestation. Some courts have ruled that asbestos claims constitute a single occurrence resulting from the decision to manufacture asbestos, while other courts have held that the claims presented multiple occurrences on the basis that each claimant constituted a separate occurrence. Some courts adopted an all sums / joint and several approach to allocation, while others took a pro rata / time on risk approach.

    The claims brought by the early plaintiffs were generally products claims. Because most policies contained aggregate limits for product claims, coverage was often quickly exhausted. In response to this reality, plaintiffs’ attorneys began to file non-products, or premises and operations, claims which alleged that plaintiffs were exposed to an asbestos-containing product at the insured’s facilities. Most policies did not contain aggregate limits for premises/operations claims.

    Some companies facing bankruptcy due to asbestos claims attempted to utilize a provision in the Bankruptcy Code, Section 524(g), which allowed a company to rid itself of current and future asbestos liability by channeling the liability into a trust, meaning that the company negotiated a global settlement with current plaintiffs and created a plan to pay future claimants, and contributed its insurance assets to fund the trust. Insurers were not generally parties to these agreements. These bankruptcies, known as prepacked bankruptcies or prepacks, offered companies a quick and relatively easy way to resolve their asbestos liabilities and emerge from bankruptcy. Insurers did not like prepacks because payouts that would otherwise take years could be accelerated. Some courts denied approval for prepacks, contending that they were not fair to all claimants and that they excluded insurance companies from participating.

    Litigation

    Certain asbestos-related cases and legislative actions are notable for their impact on the insurance industry.

    Cases

    In 1982, Johns-Manville was forced by the volume and cost of asbestos claims to file for bankruptcy protection. In 1988, Johns-Manville reorganized and created the Manville Personal Injury Settlement Trust, an asbestos trust intended to provide funds for future claims. As of 2016 the trust had paid out billions and was still paying out.
    In 1985, the Owens-Corning Fiberglass Corporation created a vehicle for resolving numerous coverage disputes with its producers and insurers over pending asbestos litigation known as the Wellington Agreement. As part of the Agreement, confidential arbitrations took place and much evidence was created under the confidentiality umbrella, something that led to new legal questions. In a 2016 Delaware state court case, Continental Cas. Co. v. BorgWarner, No. N15M-05-009, 2016 Del. Super. LEXIS 132 (Del. Super. Mar. 15, 2016), reconsideration denied, No. N15M-05-009, 2016 Del. Super. LEXIS 344 (July 14, 2016), the issue was one of access to evidence of industry custom and practice with respect to how defense costs were typically paid in asbestos claims. A non-signatory to the Wellington Agreement sought to obtain deposition and trial testimony and other evidence from one of the Wellington arbitrations to use in its own coverage dispute; of particular interest was evidence from another insurer involved in the same defense costs consent issue. Some of the sought-after materials had been discussed in a case that came before the U.S. Court of Appeals for the Third Circuit following a Wellington Agreement arbitration, North River Ins. Co. v. CIGNA Reinsurance Co., 52 F.3d 1194 (3d Cir. 1995). Ultimately the court required the production, under confidentiality, of the materials that had been publicly disclosed, released or used in other litigation; material that had not been previously made public was exempt from disclosure.

    Sec. 524(g) Trusts

    The impact of trusts set up by bankrupt asbestos manufacturers on asbestos injury litigation has come under examination by state and federal legislators.
    Companies making asbestos-containing products often file for bankruptcy protection using U.S. Bankruptcy Code Sec. 524(g) to establish trusts to pay claimants, bringing up the issue of how to allocate fault to the non-bankrupt companies involved in litigation. Generally, the company declaring bankruptcy creates a trust distribution process (TDP) which does not assign fault and only requires that allegedly injured parties file a claim form and diagnostic medical report, after which a fixed-amount payment is issued. In some cases, however, plaintiffs will make claims against the viable companies but not a claim against a bankrupt company that has created a trust, meaning that certain alleged exposures will not be discovered during litigation. The plaintiff may attempt to recover the full amount claimed from still-viable companies then later seek to recover additional amounts from the bankruptcy trusts for the same injury, effectively double-dipping.
    In response, several states have passed legislation requiring plaintiffs to disclose any claims made against trusts during litigation; some states require the disclosure before a trial date may be set.
    In February 2017, HR 906, the “Furthering Asbestos Claim Transparency (FACT) Act of 2017” was proposed with the intention of amending the U.S. Bankruptcy Code to require that 524(g) trusts publicly disclose detailed information regarding the receipt and disposition of claims for asbestos-exposure injuries. The legislation did not pass.

    Future Outlook

    Asbestos litigation continues today, particularly related to mesothelioma, meaning that insurance coverage remains important to both companies and claimants. Some experts, however, predict that asbestos-related cases may peak relatively soon in view of the asbestos regulation timeline, while some litigation is likely to continue because of the continued use of asbestos. An industry consultant noted in 2018 that claims were being settled for less in 2017 than the year before, the number of claims resolved declined, indemnity payments were historically consistent, reserves were flat, and new claim filings declined slightly for the third year in a row.

    In the News

    2024

    2023

    2022

    2021

    2020

    2019

    2018

    • Appellate court reverses $4.6M asbestos verdict in McLean County case - Edith Brady-Lunny, Pantagraph.com (09/15/2018)
      A $4.6 million verdict returned by a McLean County jury in an asbestos-related lawsuit involving a Colfax man has been reversed by the 4th District Appellate Court. . . . Charles McKinney filed the claim against Hobart Brothers Co. alleging he was exposed to asbestos from welding rods when he worked for Portable Elevator Co. . . . The jury award was returned following a 2016 trial. . . .In his lawsuit, McKinney argued that Hobart Brothers failed to warm him of the hazardous materials on welding rods that were located near his work area for about eight months in the early 1960s. . . . In its recent ruling, the appellate court found that Hobart Brothers had no duty to warn McKinney of the hazard because the company was unaware of the risk.
    • EPA's new asbestos rule: Philadelphia doctors cite the dangers - Ian Haydon, Philly.com (08/10/2018)
      With the threat of cancer-causing asbestos making a comeback in the U.S. thanks to changing environmental protection policy, local experts are sounding the alarm over a health issue that has long burdened the region. . . . Philadelphia and asbestos go way back. . . .Prized for its heat-resistance and strength, asbestos — woven of naturally occurring silicate crystals — has long been used as insulation and fireproofing in many types of buildings. It is still crumbling in older structures including Philadelphia public schools, sending disease-causing fibers into the air people breathe and onto the surfaces they touch. It was used extensively in shipbuilding, a major industry in Philadelphia.
    • New test: 10.7 million asbestos fibers on floor at Philadelphia elementary school - Wendy Ruderman, Barbara Laker & Dylan Purcell, The Inquirer (06/06/2018)
      Shortly after the School District of Philadelphia learned of alarming levels of asbestos fibers on the floor of a highly traveled hallway inside Olney Elementary School, officials said, they sent an environmental team to fix the problem. . . . But four months later, the hazard is not gone. In fact, it’s worse. Tests there revealed 10.7 million asbestos fibers per square centimeter, up from 8.5 million. . . . That latest result is more than 100 times higher than the level that health experts say is cause for alarm

    2017

    • Verdict Against New England Insulation - Sandy Smith, EHS Today (10/04/2017)
      A Superior Court jury in Boston returned a verdict of $6.8 million dollars against New England Insulation, a Canton company that distributed and installed asbestos insulation material until the early 1970s. Former Massachusetts insulator Timothy Ross passed away due to mesothelioma, an asbestos-related cancer, on Aug. 19, 2013. His widow, Amy Ross, pursued this case individually and on behalf of his estate.
    • Connecticut Appellate Court Issues Mixed Ruling on Coverage for Asbestos Liabilities - Jones Day (03/13/2017)
      Manufacturers with asbestos liabilities should pay attention to the March 7, 2017, ruling in R.T. Vanderbilt Company v. Hartford Accident and Indemnity Company by the Connecticut Appellate Court. While the court issued policyholder-friendly rulings on the issues of trigger of liability, allocation of liabilities, and the application of the pollution exclusion, the court ruled against policyholders on the application of the occupational disease exclusion. . . . The occupational disease holding is unprecedented and policyholders can expect to see insurers make a nationwide effort to extend this ruling

    2016

    • U.S. Steel accused of exposing workers to asbestos - ALEX NIXON, TribLive (08/08/2016)
      U.S. Steel Corp. is facing fines totaling $170,000 after federal regulators accused the company of giving some workers at its Clairton Coke Works tasks that exposed them to asbestos. . . . The Occupational Safety and Health Administration said this is the second time since 2011 it fined U.S. Steel for exposing employees to asbestos hazards. In 2011, the government cited U.S. Steel for seven violations at the Clairton plant and fined the company $6,750.

       

    • Sonoma State University focus of asbestos-related lawsuit - Clark Mason, Santa Rosa Press Democrat (04/15/2016)
      A longtime Sonoma State University employee’s lawsuit is raising questions about asbestos contamination on campus amid allegations that supervisors ignored his warnings about the problem and then retaliated against him when he reported it to authorities.
    •  Knox County settles asbestos lawsuit with widow of late teacher - Megan Boehnke, Knoxville News Sentinel (04/12/2016)
      Knox County has reached a "tentative settlement" with the widow of a former South-Doyle High School teacher who died from mesothelioma, officials said Tuesday.

    2015

    2014

    2013

    • Chain-Smoking Congresswoman's Asbestos Suit Shows New Trend - Daniel Fisher, Forbes (11/26/2013)
      New York Congresswoman Carolyn McCarthy, a 69-year-old Democrat, spent 30 years as a nurse before being elected to the U.S. Congress, and reportedly was a heavy smoker for more than 40 years. Yet McCarthy is seeking money from more than 70 asbestos companies, saying she was actually sickened by asbestos fibers carried home on the clothes of father and brothers, who worked on navy ships and in utilities.

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