Speaking Out: The Most Important Issues

Why emergency response and preparedness, permissible exposure limits and small business assistance present critical challenges and opportunities to the EHS community.

Every other year, leaders of the American Industrial Hygiene Association (AIHA) put together a "Top Ten" list of public policy issues, which can be viewed at www.aiha.org/GovernmentAffairs-PR/html/ga-toptenissues.htm. This list is used to prioritize the allocation of resources within the AIHA budget. I have chosen three of the Top Ten issues for discussion in this column because I believe that they are extremely important to the industrial hygiene and safety community, the United States and the world.

Emergency Response and Preparedness

The concern for emergency preparedness illustrates that occupational and environmental health and safety (OEHS) professionals are more important than ever. We are in a position to play key roles in protecting our communities, our organizations and our nation. We are in a position to be both the technical and the managerial leaders for many vital issues including, for example: air monitoring method development, the use of air monitoring methods during emergencies, the establishment of evacuation zones, the use of personal protective and decontamination equipment, the development and application of decision logic for emergency response, and risk communication to the affected public. It is naïve to believe that fire departments, state police and the Federal Emergency Management Agency can evaluate and control emergency situations without the assistance and leadership of the hygiene and safety community. We have the opportunity to step up and take a leadership role.

It is important our professional community understands that this issue represents an opportunity to serve our country. Although only a small fraction of us wear the uniforms of our armed forces, we can all play a part. Safety and hygiene professionals can play vital roles in defending America and our allies during public hygiene emergencies that would be precipitated by biological, chemical, nuclear or, as we saw on 9/11, other types of attacks. And, as many of you know, historically more military personnel are lost or injured by non-combat causes than by enemy action. Thus, safety and hygiene personnel play a vital role in defending our country and allies whether or not we wear a uniform.

Tom Grumbles, AIHA's president-elect, plays a role in his company in implementing the American Chemistry Council's (ACC) new Security Code, which is an important step in the war on terrorism (www.responsiblecaretoolkit.com/security_code.asp#Form). The ACC's efforts to protect vital assets are central to the security not only of our chemical industry, but to the economy of the world's democracies as a whole. Grumbles, as a senior hygienist in his company, the immediate past chair of the ACC's Responsible Care team, and as an officer of AIHA, has both an important technical and leadership role in this aspect of industrial and civilian defense.

Donna Doganiero, AIHA's vice president, is a central player in the U.S. Army's safety and hygiene programs (chppm-www.apgea.army.mil). As director of occupational health sciences at the Army Center for Health Promotion and Preventive Medicine, she led her staff in the development of the "Medical NBC Battlebook" which has become the "bible" of the U.S. Army in addressing operational health concerns in environments where nuclear, biological and chemical threats exist. Addressing such threats was always important to our military preparedness, and of course became more important after 9/11 and the widespread deployment of our armed forces. Current events have resulted in the development by her staff of additional guidance directed towards hospital personnel. The document "Personal Protective Equipment Guide for Military Medical Treatment Facility Personnel Handling Casualties from Weapons of Mass Destruction and Terrorism Events" is in final editing and is slated for publication this summer.

These two leaders of our profession are good examples of ways in which we can serve our country.

In addition, the issue of emergency response and preparedness is an opportunity to obtain funding for previously under-funded public health projects. Many such projects, spanning an enormous range of subjects from air monitoring for chemical agents to the training of emergency response teams, can now be funded as never before. Of course it is our responsibility that these funds not be wasted on pet projects, but be used for the common good.

Updating Permissible Exposure Limits

Many of OSHA's Permissible Exposure Limits (PELs) have not been updated since the 1970s. Science in this area has matured, but the PELs have not. "AIHA's White Paper on Permissible Exposure Limits (PELs)", dated Sept. 29, 2002, can be viewed at www.aiha.org/GovernmentAffairs-PR/html/GAWPpermexpo.htm. AIHA continues to facilitate a working group of industry and labor in reaching a consensus on the best way to update the PELs. The working paper being finalized will provide details on how a legislative fix could work. This has been an ongoing project since AIHA President Gayla McCluskey identified this subject when she first became AIHA vice-president almost three years ago.

Aaron Trippler, AIHA's director of government affairs, comments: "Will anything happen on this issue? It will be very difficult, but not impossible, to see legislation introduced that would provide the first step in solving this problem. Rep. Charlie Norwood of Georgia has expressed an interest in updating the PELs. On the Senate side, Sen. Michael Enzi (R-Wyo.) has hinted that he may be interested in taking a look at the issue. Of course, looking at the issue is much different than actually enacting some legislation. This is one of those issues that sound good, but the devil is in the details."

Indeed, the details are daunting. The primary underlying problem is that of different definitions of "permissible." OSHA's definition requires a test of any limit for technological and economic feasibility, and requires that there be quantitative support for any contention that a specific reduction in exposure limit will result in a corresponding specific reduction in illness. NIOSH's criteria rest on the simple supposition that no worker shall experience any adverse health effect. ACGIH's criteria say "almost all" workers shall be protected, but specific definitions of "almost" are hard to come by. In fact, it appears that ACGIH may be slowly but surely gravitating towards a No Observable Effect Level or Lowest Observable Effect Level without ever having a formal change in the policy of "almost all."

These three sets of criteria from the three primary players in the game of setting occupational exposure limits (OELs) are a difficult and, some say, intractable issue that must be overcome for any progress to be made. Why must progress be made? The answers are numerous: 1) Many of the OSHA PELs are outdated; 2) The NIOSH RELs are not widely used; and 3) The ACGIH process and criteria have come under widespread criticism as being inadequately defined, implemented and documented, even as they have become the default OELs that have been formally or informally adopted by organizations both in the United States and worldwide. This situation lends itself to a future filled with litigation over OELs that are too high, too low, entirely missing and/or unsupportable. It is a problem that must be solved.

OEHS Small Business Assistance

"In the 107th Congress, legislation was nearly passed that would have provided for assistance to small business in how to comply with federal regulations, including health and safety. The bill has been reintroduced in the 108th Congress. AIHA was successful in seeing that the legislation assures that competent hygiene and safety individuals would provide this training," says AIHA's Trippler. Grumble's testimony, dated July 2001, can be viewed at www.aiha.org/GovernmentAffairs-PR/html/gahr203.htm.

There has been and continues to be interest in issues to assist small business in the United States and elsewhere. With the worldwide spread of the requirement for management systems auditing and registration of suppliers and contractors, small businesses will be positively impacted for hygiene and safety issues. How does this work? Customers require suppliers and contractors to pre-qualify for bidding on contracts by attaining registration, or some other measurable objective, in the fields of quality systems, environmental management and occupational health and safety management. Even in the absence of specific regulations, this movement will gain momentum worldwide and ultimately result in improved practice of hygiene and safety at small businesses, and improved opportunities for our professional practice both in the United States and worldwide.

Contributing Editor Steven P. Levine, Ph.D., CIH, is a professor of environmental health sciences at the University of Michigan and adjunct professor at the Institute of International Health at Michigan State University. He is a past president of the American Industrial Hygiene Association.

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