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THE
      Synergist
                                                            ®




12/10                                        www.aiha.org




Improve Your Graphics
                                                    Does your data show
                                                      the forest or the trees?




 8    Building IH Capacity in the U.S.
22    Do “Zero-Risk” Exposures Exist?
27    ISO’s Social Responsibility Standard
29    The Business Case for OHS Databases
Circle Fax-back Card No. 2
Synergist
                                      ®
    THE




                                          Features
                                          24 Extreme Makeovers
                                             A longtime EHS pro shares simple
                                             tips for making your data come alive.
                                             By Ed Rutkowski


                                          27 Contentious Consensus
                                             Input from a diverse group of
                                             stakeholders will add to the credibility
                                             of ISO’s new standard on social
                                             responsibility.
                                             By Jeffrey Hogue


                                          29 Streamlined Management
                                             How to build a business case for OHS
                                             databases.
                                             By Monica Melkonian




24




27
4     The Synergist I December 2010
                                                                    29
Circle Fax-back Card No. 3
®




                                                                                                       THE
                                                                                                             Synergist
                                                                                                                        Volume 21 I Number 11
Columns & Departments                                                                                                 Editor in Chief
                                                                                                        Constance Paradise, CAE: cparadise@aiha.org
                                                                                                                        Managing Editor
                                                                                                                Ed Rutkowski: erutkowski@aiha.org
                                                                                                                        Assistant Editor
                                                                                                                 Brooke Morris: bmorris@aiha.org
                                                                                                        Senior Manager, Periodicals and Technology
                                                                                                               James Myers: jmyers@aiha.org
                                                                                                               Creative Services Associate/Designer
                                                                                                                 Billy Stryker: bstryker@aiha.org
                                                                                                                    Advertising Representative
8     President’s Message                                                                                             Network Media Partners
      Building Industrial Hygiene                                                                                          Ben Ledyard:
                                                                                                               bledyard@networkmediapartners.com
      Capacity in the United States
      By Michael T. Brandt                                                                                               Executive Director
                                                                                                               Peter J. O’Neil, CAE: poneil@aiha.org
10 Letters                                                                                             The Synergist ® is a copyrighted publication of the American
      Revisiting the Haiti Earthquake                                                                  Industrial Hygiene Association, 2700 Prosperity Ave., Suite
                                                                                                       250, Fairfax, VA 22031; (703) 849-8888; e-mail synergist@
12 NewsWatch                                                                                           aiha.org. No part of The Synergist may be reprinted without
                                                                                                       the express written consent of AIHA. Submission of articles
      OEHS AND INDUSTRY NEWS                                                                           or letters to the editor are welcome, but AIHA and The Syn-
                                                                                                       ergist will determine what to publish and reserve the right
20 Insight: Exposure Assessment                                                                        to edit all submissions for content, style, length and clarity.
                                                                                                           The Synergist (USPS #009-332) is published monthly ex-
      Time for Modeling                                                                                cept a combined June/July issue by the American Industrial
      By Steven D. Jahn                                                                                Hygiene Association, 2700 Prosperity Ave., Suite 250, Fairfax,
                                                                                                       VA 22031 for $50 per year for members; nonmembers may
22 Insight: Risk Assessment                                                                            subscribe for $275/yr. International nonmembers may subscribe
                                                                                                       for $375/yr (U.S. funds). Periodicals postage paid at Fairfax,
      Crossing a Threshold                                                                             Virginia, and additional mailing offices. POSTMASTER: Send
      By Frank Mirer                                                                                   address changes to The Synergist, American Industrial Hygiene
                                                                                                       Association, Attn: Customer Service, 2700 Prosperity Ave.,
                                                                                                       Suite 250, Fairfax, VA 22031. ISSN 10667660.
32 Community                                                                                               Publications Mail Agreement No. 40039445. Return
      AIHA NEWS                                                                                        undeliverable Canadian addresses to PO Box 503,
                                                                                                       RPO West Beaver Creek, Richmond Hill ON L4B 4R6.
35 Opportunities                                                                                                  Editorial Advisory Board Members
      EDUCATIONAL EVENTS FOR                                                                                 Jeff Behar, California Institute of Technology
      OEHS PROFESSIONALS                                                                                                 Wendell Britnell, LMI
                                                                                                                     Patricia Crawford, Consultant
36 Product Features                                                                                                M. Cathy Fehrenbacher, U.S. EPA
                                                                                                                          Don Garvey, 3M Co.
                                                                                                                    Stephen Hemperly, Hitachi GST
37 Advertisers’ Index/
                                                                                                                       John Mazur, MACTEC Inc.
   Synergist Fax-Back Card                                                                                      Hank Muranko, Muranko & Associates
                                                                                                              Doris Reid, Saxe Colman Consulting Group
38 Introductions

                                                                               12
                                                                                                             John Rekus, John F. Rekus & Associates Ltd.




COMING IN JANUARY I Wood-dust Exposures I Survey of OEHS Professionals I Smart Phones: Data Security and Privacy Concerns



    The Synergist’s mission is to provide AIHA members with news and information about the occupational and environmental health and
    safety fields and the industrial hygiene profession. The Synergist focuses on industry trends and news, government and regulatory
    activities, key issues facing the profession, appropriate technical information and news on association events and activities.
       The Synergist’s objective is to present information that is newsworthy and of general interest in industrial hygiene. Opinions,
    claims, conclusions and positions expressed in this publication are the authors’ or persons’ quoted and do not necessarily reflect the
    opinions of the editors, AIHA or The Synergist.



6            The Synergist I December 2010
Circle Fax-back Card No. 4
COLUMN | PRESIDENT’S MESSAGE




President’s Message

Building Industrial Hygiene
Capacity in the United States
BY MICHAEL T. BRANDT, AIHA® PRESIDENT




We are well acquainted with the chal-       Impact on AIHA                              their lesson plans to demonstrate how
lenge of replacing current industrial hy-   The report’s findings are both alarming     science and math are used to solve
gienists as they retire. In fact, other     and relevant to AIHA. Who will be IHs       crimes, remediate disasters such as Katrina,
science, technology, engineering, and       in the future? How will they be re-         protect and rescue workers such as the
medical (STEM) professions are experi-      cruited? Where can we find qualified        Chilean miners, clean up oil spills, and
encing the same challenge and searching     candidates? Will there be enough quali-     prevent accidents.
for ways to counter the following trends    fied and competent IH practitioners?           While K-12 education in America is a
in U.S. education:                             The report contends that if teachers     national concern, our system of education
                                            are better qualified to teach science and   consists of 14,000 local school systems.
• K-12 education lags behind that of        math, then the number of students quali-    Each of us lives in a community where
  other developed nations, despite a        fied to enter STEM fields will increase.    our children attend school. Solving this
  higher cost per student than any other    As AIHA members, we need to ask our-        problem begins in our communities. Solv-
  OECD (Organization for Economic Co-       selves, “What have we done to improve       ing this problem begins with each of us!
  operation and Development) country.       STEM education in our communities?”            If we are to achieve our mission of
• Junior and senior high school stu-        Opportunities to make a difference are      “Creating knowledge to protect worker
  dents are inadequately prepared in        plentiful. Personally, I have volunteered   health,” we need to ensure that ours is a
  math and science.                         at three graduate schools to teach envi-    vibrant profession that attracts well quali-
• 78 percent of high school graduates       ronmental and occupational health, in-      fied students and early-career profession-
  do not meet the readiness benchmark       dustrial hygiene, finance and other         als. Sharing our experiences with young
  levels for one or more entry-level col-   courses. I have also visited middle and     minds that are searching for purpose is a
  lege courses in math, science, reading,   high schools in my community to intro-      good start. If each of our 10,000 members
  and English.                              duce students to industrial hygiene and     stimulated just one student to study math
                                            generate interest in math and science.      and science throughout high school and
• Fewer college students are receiving         AIHA National has invested member        then college, we would increase the talent
  undergraduate degrees in science or       equity over the past ten years to recruit   pool for all STEM fields. I encourage each
  engineering.                              and mentor early-career IHs. But our        of you to get involved with your local
                                            new memberships are not keeping pace        schools either individually or as a local
   These statistics are found in the re-
                                            with retirements. The report from NAS       section with an action plan. Change begins
cently released National Academy of
                                            is further confirmation that unless we      with the first step.
Science (NAS) report “Rising Above the
                                            reverse current trends, there won’t be
Gathering Storm, Revisited.” (A free PDF
                                            enough qualified IHs to replace retiring    Michael T. Brandt, DrPH, CIH, PMP, is technical chief
of the report is available from www.nap.                                                of staff for Operations at Los Alamos National Labo-
                                            IHs, let alone grow the profession.
edu.) This update of the original 2005                                                  ratory in Los Alamos, N.M. He can be reached at
study assesses the principal ingredients                                                (505) 667-1228 or mtbrandt@lanl.gov.
of innovation and competitiveness—          Local Outreach
                                            I challenge each local section to reach       Resources for Outreach
knowledge capital and human capital.
                                            out to middle- and high-school teachers.
NAS research shows that funding of                                                        to Students
                                            Offer to help them generate enduring in-
R&D as a percentage of GDP has de-
                                            terest in the application of scientific       Visit the AIHA website at
clined more than 60 percent in the past                                                   www.aiha.org/insideaiha/students/
                                            principles to solve real-world problems.
40 years, and only 4.5 percent of Ameri-                                                  Pages/StudentOutreachMaterials.
                                            Since the average K-12 student spends
can college students are earning degrees                                                  aspx for information related to
                                            four hours each day watching TV, we
in engineering.                                                                           conducting outreach to students.
                                            could help teachers incorporate IH into


8          The Synergist I December 2010
Circle Fax-back Card No. 5
COLUMN | LETTERS




Lettters

Revisiting the Haiti Earthquake
 To the Editor:                                                                             Hornsby-Myers responds:
 This is in response to the article “The Next Day, Everything Was Flat” (October            I appreciate the comments of LTC Goff
 issue) in which Managing Editor Ed Rutkowski interviews Jennifer Hornsby-Myers             and MAJ Carter of the U.S. Air Force,
 from NIOSH. Ms. Hornsby-Myers deployed to Haiti with the CDC as a public health            and I also appreciate the opportunity to
 liaison to Joint Task Force-Haiti (JTF-H). While we laud her work, she doesn’t have        clarify an off-the-cuff general com-
 all her facts straight, specifically regarding the military’s capability to provide pub-   ment in my Synergist interview that
 lic health support. While she is correct in saying public health is not the military’s     prompted the letter concerning my de-
 primary mission, she completely misses the mark in saying the military doesn’t             ployment to Haiti. I certainly did not
 have many public health assets. The Air Force takes great pride in its robust public       intend to imply that the Department of
 health, environmental health and industrial hygiene assets. JTF-Haiti was no dif-          Defense does not have public health
 ferent with this support.                                                                  assets. My comment was intended to
     When Air Force Special Operations Command personnel landed in Port-au-                 delineate between the overall mission
 Prince on Jan. 13, 2010, there was a public health officer and preventive-medicine         of the DoD and the CDC, not the spe-
 physician on the very first plane as part of the team of command and control,              cific assets of each group. From my
 combat controllers, and para-rescue personnel to open up the airport and begin             personal experience during my deploy-
 search and rescue operations. On Jan. 14, 2010, there was an Air Force industrial          ment, all of the services that make up
 hygiene technician on the ground. The three made up what we call a Special                 the DoD did an outstanding job of sav-
 Operations Forces Medical Augmentation team and immediately began vector                   ing lives and providing security post-
 and rodent control, drinking water sampling, hazardous noise characterizations,            earthquake—as did all of my colleagues
 heat stress monitoring, proper hazardous waste and used oil storage work.                  in the U.S. Public Health Service.
 Within a week, and then a month, as more conventional forces arrived (called                  The intended message of this part of
 Global Reach Laydown and Preventive Aerospace Medicine teams), more public                 the article was to highlight the valu-
 health and industrial hygiene assets came with the rescue personnel and surgeons.          able partnership that existed between
 With them came more air, water, noise, and vector sampling equipment, with                 the CDC and the DoD through the JTF-
 which they were very busy evaluating and providing advice to JTF leadership on             H (Joint Task Force-Haiti). This was the
 risk control measures.                                                                     first time, to my knowledge, that CDC
     As a force within the Air Force, there are on average 10–20 Public Health Air-         had a liaison to a JTF during a foreign
 men, 10–20 environmental health/industrial hygiene Airmen (the Air Force calls             disaster. It proved to be a very benefi-
 them Bioenvironmental Engineers), and 2–3 physicians trained in occupational/              cial relationship not only for the CDC
 preventive medicine at each base around the world, and a smaller number at each            and the DoD but for the overall mis-
 deployed location in the Middle East and South Asia supporting our operations.             sion of providing vital assistance to the
 While we can’t speak for the Army, Navy, or Marines (and we hope they comment              Haitians who were (and are) suffering
 on this article), we can say without a doubt that the Air Force has many robust            so greatly. I sincerely hope that the
 public health, environmental health, industrial hygiene, and preventive medicine           Haitian relief effort will be a model for
 assets, both at our “home bases” and our deployed locations.                               any future foreign disasters, including
                                                                                            a CDC Liaison to the JTF.
 Lt. Col. Philip Goff, CIH, Command Bioenvironmental Engineer for Air Force
 Special Operations Command, who provided command oversight for JTF-Haiti Air               CDR Jennifer Hornsby-Myers, MS, CIH
 Force preventive medicine forces.                                                          CDC Liaison to JTF-H
                                                                                            United States Public Health Service
 Major Rebecca Carter, PhD, deputy flight commander of the 96th Aerospace Medi-             CDC/NIOSH
 cine Squadron Bioenvironmental Engineering Flight, Eglin Air Force Base, Florida,
 who deployed to JTF-Haiti with a Preventive Aerospace Medicine Team.




10         The Synergist I December 2010
The Occupational Environment:
                   Its Evaluation, Control,
                   and Management,
                   3rd Edition
                                               An essential core reference for OEHS practitioners,
                                               educators, and students, the newly revised 3rd edi-
                                               tion includes information on hazard recognition and
                                               evaluation, physical agents, program management,
                                               and more. Most chapters have been rewritten and
                                               updated to include the most current information
                                               available in a single OEHS reference.

   Volume 1 focuses on chemical aspects, air monitoring, and exposure and risk
   assessment strategies. Volume 2 includes content related to the physical hazards,
   control methods, and management aspects. Several new chapters have been added
   to cover nanotechnology, ethics, IH issues in construction, the AIHA Value Strategy
   business model, and more.



   Complete Set: BIHT10-566 ...............................Member Price: $229 ..............Nonmember Price: $309
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    THE

          Synergist
                                                                                   ®




Preparing for January
    10/11                                                        www.aiha.org




Washington Insider
By Aaron Trippler, Director, AIHA® Government Affairs




The voters have spoken, and Washington is prepar-           OSHA Reform
ing for another session of a Congress that will look        Under a Republican-controlled House, OSHA is unlikely
much different from the one about to conclude.              to receive additional authority to impose regulations on
The ramifications of the midterm elections will affect      employers. Republicans have hinted they are unwilling to
legislative action in Congress and occupational health      consider substantial changes to the way OSHA operates
and safety activity at the agency level. At the very        and have already announced there will be more oversight
least, changes in legislative leadership will affect the    of regulatory agencies. Of course, industry hopes the
OHS agenda.                                                 House will go even further than simple oversight and stop
                                                            several activities within OSHA.
                                                            The following issues may come up for discussion during
Leadership                                                  the new Congress:
Leadership in the Senate will likely remain as is: Expect   Mine Safety and Health. Republicans may sit down with
Senator Tom Harkin to remain chairman of the Health,        Democrats and work out a bill that would provide addi-
Education, Labor and Pensions (HELP) Committee and          tional health and safety measures in the mining industry.
Senator Patty Murray to remain chairwoman of the sub-       Whether this bill will go as far as the bill introduced in
committee that oversees OSHA. Senator Mike Enzi is also     2010 is unclear.
likely to continue as the Republican leader on the HELP
                                                            Injury and Illness Prevention Program Rule. Industry
Committee.
                                                            may work with House leadership to stop OSHA’s efforts
The House leadership will experience considerable           to enact an injury and illness prevention program rule.
change. Rep. George Miller is out as chairman of the        The most obvious way to stop agency efforts is through
House Education and Labor Committee, with Rep. John         the appropriations process.
Kline the likely successor. Who might chair the subcom-
                                                            MSD 300 Log Addition. Industry will also work to enlist
mittee with OSHA oversight has yet to be determined,
                                                            the support of Republicans to stop OSHA from moving
but Rep. Lynn Woolsey is out.
                                                            forward on this proposal, which industry views as a “back



                                                                    The Synergist | December 2010               DE 1
SPECIAL TO THE DIGITAL EDITION


door” approach to ergonomics. However, adding an MSD         on OSHA and its efforts to regulate employers. Both
column on the OSHA 300 log has numerous supporters           groups are probably wrong. In the last two years, no leg-
who will argue that OSHA should be allowed to continue       islation to address workplace health and safety was en-
its efforts.                                                 acted, so it’s not like the Republicans have anything to
                                                             repeal. And the Republicans will likely be unsuccessful in
Voluntary Protection Program (VPP). Republicans may
                                                             many attempts to limit agency oversight.
work to enact legislation that would codify and perma-
nently fund the Voluntary Protection Program. This ap-
proach enjoyed bipartisan support in the previous session    What about OSHA?
of Congress. OSHA had hoped to convince Congress that
the VPP should be user funded. Expect any OSHA appro-        OSHA will continue to pursue its agenda, but this won’t
priations measure to include continued funding for VPP.      be quite as easy as before the election. Industry is much
                                                             more empowered to oppose OSHA efforts and will at-
NIOSH. What the new Republican leadership might do           tempt to stop, or at least slow, agency activity. Most no-
with NIOSH is unclear. While some Republicans believe        tably, OSHA will have even more difficulty addressing
these types of agencies need to be shut down, just as        anything remotely related to ergonomics. The Injury and
many recognize their value. AIHA® has been meeting           Illness Prevention Program (I2P2) rule may also face
with other stakeholders to discuss possible efforts to en-   problems from industry, which has already approached
sure that NIOSH is funded and protected. One possibility     members of the House about stopping this program,
is to have the Government Accountability Office study        most likely through appropriations.
the pros and cons of keeping NIOSH within the organiza-
tional structure of the Centers for Disease Control and      Agency activity on other issues will continue but likely at
Prevention (CDC). AIHA believes there is support for such    a slower pace. OSHA will have to consider whether an ac-
a study within the GOP and within NIOSH. In a recent dis-    tivity has a reasonable chance of success before it moves
cussion, AIHA learned that CDC has appropriated nearly       forward. Issues such as VPP, changing the on-site consul-
$300 million of the NIOSH budget for CDC expenses over       tation program, and updating the PELs will all be more
the past 18 years.                                           difficult to achieve.

Appropriations. Republicans in the House will certainly
attempt to control spending. Some possibilities include      What about the States?
cutting federal employment by 10 percent, federal dis-
                                                             A considerable number of states saw a switch in party
cretionary spending by $100 billion per year, and agency
                                                             control of the governor’s office, and many of the state
spending by 22 percent. Another possibility is to cap
                                                             legislatures also saw a switch to the Republican party. It’s
spending at 2008 levels. All of these actions will be con-
                                                             hard to tell how this might impact occupational health
sidered, but the Senate is unlikely to allow such drastic
                                                             and safety in 2011. I expect states to continue to be more
changes.
                                                             inclined than the federal government to address specific
However, Republicans may place language in many of the       OHS issues. Look for the same involvement in the states
appropriations bills that limits where the dollars may be    on issues such as mold abatement, methamphetamine
spent. For example, they could adopt an OSHA budget          laboratories, Chinese drywall, and other issues that di-
that prohibits spending money on advancing an injury and     rectly impact workers and consumers.
illness prevention program rule. Any threats to agency ac-
tivity are likely to come from actions such as this.
                                                             Aaron Trippler directs government affairs for more than 70
The bottom line: many stakeholders say the new Congress      local sections and serves as AIHA’s chief liason with Congress
will be devastating for occupational health and safety,      and federal agencies. He can be reached at (703) 846-0730 or
while many others predict that Congressional limitations     atrippler@aiha.org.




                                                                      The Synergist | December 2010                  DE 2
NewsWatch
        OEHS NEWS    I   GOVERNMENT NEWS        I   INDUSTRY NEWS




STANDARDS                                                              are issued only when they cost less than a hearing conservation
                                                                       program and PPE is ineffective. In the proposed amendment to
ISO Releases Guidance Standard on Social Responsibility                its noise enforcement policy, the agency intends to sanction the
On Nov. 1, the highly anticipated ISO 26000:2010 standard,             issuance of citations requiring the use of administrative and en-
Guidance on Social Responsibility, was unveiled in Geneva,             gineering controls when feasible as noted in the interpretation.
Switzerland. The standard provides guidance to business and               “Since 1983, when the current interpretation was in place,
public sector organizations on social                                  there has been a somewhat unrealistic reliance on hearing pro-
responsibility concepts and imple-                                     tection,” says AIHA® Noise Committee Chair Joe Cissna, CIH,
mentation elements.                                                    MHS. “So we support OSHA for bringing engineering controls
   Development of ISO 26000:2010                                       more to the forefront. It follows the hierarchy of controls prin-
lasted more than eight years. AIHA®                                    ciple that underpins the industrial hygiene approach.”
participated as a D-Liaison organiza-                                     OSHA is accepting comments through Dec. 20, 2010. Com-
tion, which enabled the association to                                 ments can be submitted at www.regulations.gov, by mail, or by
take part in the formal standard pro-                                  fax to (202) 693-1648. Individuals who mail or deliver com-
ceedings and contribute to the drafting                                ments must submit three copies to the OSHA Docket Office.
process.                                                               Faxed submissions may not exceed 10 pages.
   Unlike other management interna-                                       The OSHA proposal is available at
tional standards, ISO 26000:2010 contains voluntary guidance,          http://edocket.access.gpo.gov/2010/2010-26135.htm. To read
not requirements, and is not intended for certification pur-           OSHA’s press release, visit http://bit.ly/aVEKXo.
poses.
   “The key purpose of the standard is to encourage organiza-          RESEARCH
tions to integrate social responsibility throughout their deci-
sions and activities,” states Jeffrey Hogue, who represents AIHA       Workplace Noise Increases Risk of Heart Disease,
as D-liaison expert to the ISO Working Group on Social Re-             Study Finds
sponsibility (WG/SR) and on the U.S. Technical Advisory Group          A new study conducted by the University of British Columbia’s
(TAG) to ISO Technical Committee 26000 on Social Responsibil-          School of Environmental Health in Vancouver suggests that a
ity. “Best practices include making social responsibility integral     noisy work environment can lead to heart disease. The study
to an organization’s policies, culture, strategies and operations.”    was published on the website of the journal Occupational and
For more information, see Hogue’s article on page 27.                  Environmental Medicine.
   The standard can be purchased from the ISO website,                     EmpoweredNews.net reports that, according to
www.iso.org.                                                           the study, workers exposed to a noisy environ-
                                                                       ment are two to three times more likely to de-
NOISE                                                                  velop heart disease than those who work in
                                                                       quieter environments. Authors of the study
OSHA Proposes New Interpretation for Noise Standards                   classified persistent loud noise as unwanted,
OSHA is proposing to issue a reinterpretation of the phrase            intrusive sound resonating from manu-
“feasible administrative or engineering                                facturing processes.
controls” in occupational noise exposure                                   Researchers analyzed data from 6,300
standards and to revise its current policy                             subjects who were at least 20 years old.
to reflect this interpretation. In the                                 The subjects were given physicals and blood
OSHA proposal, “feasible” will retain its                              tests and answered questions regarding their health and
common meaning of “capable of being                                    lifestyle. Researchers found that loud noises elicit stress and the
done” in order to enforce compliance                                   release of chemicals that constrict coronary arteries and can
with current noise standards.                                          cause additional heart-related illnesses.
   The existing noise standards stipulate that feasible adminis-           An abstract of the study is available at http://oem.bmj.com/
trative or engineering controls must be used to abate noise, and       content/early/2010/09/06/oem.2010.055269. To read the Empow-
PPE, such as earplugs or earmuffs, are to be worn when admin-          eredNews.net article, visit http://empowerednews.net/?p=2530.
istrative or engineering controls are insufficient. Currently, cita-
tions for failure to use engineering and administrative controls


12         The Synergist I December 2010
NEWSWATCH | DEPARTMENT



MINING SAFETY                                                            investigation, according to a report in the Wall Street Journal.
                                                                            The 33 miners were trapped more than 2,000 feet under-
Following Mine Rescue, Chilean Government Vows to                        ground for 69 days.
Better Protect Workers                                                      To read the Wall Street Journal article “Chile, in Mine Res-
The rescue of 33 miners from a collapsed mine in Copiapo,                cue’s Glow, Vows Labor Reform,” visit http://bit.ly/ad6ARZ. The
Chile, in mid-October has caused the Chilean government to               CNN.com article “After a Final Day Together, Miners Begin to
reevaluate its worker health and safety protections, according           Disband” is available at http://bit.ly/dyIXWy.
to an article posted Oct. 15 on
CNN.com. After meeting with the miners,
Chilean President Sebastian Pinera                                        MINING SAFETY
pledged to strengthen labor laws and
improve work environments. He also                                       Proposed Rule Would Reduce Exposure to Coal Dust
vowed to see that Compania Minera                                        In October, MSHA released a proposed rule that would lower
San Esteban Primera, the company                                         mine workers’ exposure to respirable coal dust in all under-
that operated the mine, would cover a                                    ground and surface coal mines. Part of MSHA’s “End Black
portion of the millions spent on rescue                                  Lung–Act Now” campaign, the pro-
efforts.                                                                 posed rule would blend previous reg-
   CNN.com quotes Pinera as saying, “Never again in our coun-            ulatory actions and implement
try are we going to permit work in such an unsafe and inhu-              recommendations in the 1995 NIOSH
mane environment as the San Jose mine. We are going to                   report “Criteria for a Recommended
create a culture of respect for life, health and dignity of our          Standard: Occupational Exposure to
workers.”                                                                Respirable Coal Mine Dust” and the
   In addition to forcing Compania Minera San Esteban Primera            1996 “Report of the Secretary of
to pay for part of the rescue expenses, the Chilean government           Labor’s Advisory Committee on the Elimination of Pneumoco-
intends to take administrative action and launch a congressional         niosis Among Coal Mine Workers.”
                                                                                                                         [Continued: 14]




                                                         Circle Fax-back Card No. 6

                                                                                               November 2010 I The Synergist           13
DEPARTMENT | NEWSWATCH

[From: 13]
   The proposed rule would reduce the existing concentration                TRAINING
limits for respirable coal mine dust from 2 mg/m3 to 1 mg/m3
over a 24-month phase-in period, require the use of continuous             OSHA Revises Policy on Training
dust monitors, enforce the utilization of a single, full-shift sam-        OSHA has modified the guidelines of its Outreach Training Pro-
ple to verify compliance, and expand medical surveillance so               grams to reduce the number of hours students spend each day
miners could better manage their health. The proposed rule also            in 10- and 30-hour training classes. The
addresses extended work shifts and production shifts.                      new policy limits classes to a maximum of
   According to data from NIOSH, cases of black lung are on                7.5 hours per day; prior to this change,
the rise. Young miners are even developing advanced and de-                classes could last up to 13 hours a day.
bilitating lung disease due to exposure to excessive amounts of            OSHA instituted this policy change to pre-
dust, and more than 10,000 miners have died from black lung                vent students from being overloaded with
within the past decade.                                                    information in a single day of training.
   To read the complete proposed rule as published in the Fed-                In accordance with the new training
eral Register, visit http://bit.ly/axmHr3. Comments are due Feb.           policy, 10-hour courses must be conducted
28, 2011, and may be submitted via the federal e-rulemaking                over a minimum two-day period and 30-
portal at www.regulations.gov, via mail to MSHA, 1100 Wilson               hour courses must be given over at least
Blvd., Arlington, Va. 22209-3939, or by fax to (202) 693-9441.             four days. OSHA will not accept classes
   To read the MSHA press release, visit                                   that do not meet all program requirements or exceed 7.5 hours
www.msha.gov/MEDIA/PRESS/2010/NR101014.pdf. Videos from                    per day. The agency has also set up an outreach fraud hotline at
MSHA’s “End Black Lung–Act Now” Campaign are available at                  (847) 725-7810 where the public can report program fraud or
www.dol.gov/dol/media/webcast/20101013-coal/.                              abuse.
   NIOSH data on black lung disease can be found at                           For more information, read the OSHA press release at
www.cdc.gov/niosh/topics/pneumoconioses/.                                  www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=
                                                                           NEWS_RELEASES&p_id=18606.




     Think all HSE
     Consultants &                                                         1. Ye
                                                                                 ars o
     Laboratories                                                         2. U.
                                                                                S. lo
                                                                                       f exp
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                                                                                      catio
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                                                                      6. # o                    ved
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                                                                 8. Ded
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                                                                9. Pr                servic
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                                                                           ional                 ?
                                                                                 Licen
                                                                                      ses




                                                           Circle Fax-back Card No. 7

14         The Synergist I December 2010
NEWSWATCH | DEPARTMENT



 NACOSH                                      chlorine, said Charles E. Adkins, OSHA        ENFORCEMENT
                                             Regional Administrator, Kansas City, Mo.,
Labor Department Renews National             in an agency press release.                   OSHA Launches Inspection Plan for
Safety and Health Advisory Commit-              OSHA claims the garrison willfully vio-    High-Hazard Workplaces
tee Charter                                  lated procedures by supplying workers         In August, OSHA began its annual in-
In October, Secretary of Labor Hilda L.      who were changing chlorine cylinders          spection of high-hazard work sites under
Solis renewed the                            with five-minute emergency escape             the Site Specific Targeting 2010 (SST-10)
charter of the OSHA                          breathing devices. OSHA procedures for        program. The plan is intended to help
National Advisory                            working with hazardous chemicals require      OSHA channel its enforcement resources
Committee on Occu-                           self-contained breathing apparatus or         into workplaces with the highest rates of
pational Safety and                          supplied-air respirators.                     injuries and illness.
Health (NACOSH).                                The garrison can comply with the no-          “Our goal is to prevent worker injuries
NACOSH advises,                              tice, request an informal meeting with the    and illnesses and save lives,” said Assis-
consults with, and                           OSHA director in Wichita, Kan., or ask for    tant Secretary of Labor David Michaels in
makes recommenda-                            a hearing with the regional administrator     an OSHA press release. “The Site Specific
tions to secretaries of                      in Kansas City.                               Targeting program helps OSHA focus its
labor and the Department of Health and          The OSHA press release is available at     enforcement resources to high-risk em-
Human Services (HHS) on issues concern-      http://bit.ly/cVut3W.                         ployers who are endangering their work-
ing the OSH Act and improvements to                                                        ers’ health and safety.”
workplace health and safety protections.                                                      The OSHA SST program inspects non-
   “Since OSHA’s inception, NACOSH has        RECORD KEEPING                               construction workplaces with 40 or more
played an important role in advising the                                                   employees. Based on work-related injury
                                             Nonfatal Workplace Injuries and
secretaries of labor and HHS on worker                                                     and illness data compiled from a 2009
                                             Illnesses in Private Sector Down in
safety issues such as hazard communica-                                                    OSHA survey, SST-10 randomly selects
                                             2009, BLS Reports
tion, the whistleblower program and                                                        establishments from a list of 4,100 manu-
                                             According to the Bureau of Labor Statis-
providing ideas and input on ways to re-                                                   facturing, nonmanufacturing, and nursing
                                             tics (BLS) 2009 Survey of Occupational
duce worker deaths, injuries and ill-                                                                                  [Continued: 16]
                                             Injuries and Illnesses, nonfatal workplace
nesses,” said Assistant Secretary of Labor
                                             injuries and illnesses among workers in
David Michaels in an OSHA press re-
                                             private industry decreased to 3.6 cases per
lease. “The members’ advice and recom-
                                             100 equivalent full-time employees in
mendations are extremely valuable
                                             2009—a decline from 3.9 cases in 2008.
because they have a wealth of knowl-
                                             Nonfatal occupational injuries and ill-
edge and real-world experience on a
                                             nesses dropped from 3.7 million cases in
wide range of worker health and safety
                                             2008 to 3.3 million cases in 2009. In ad-
matters.”
                                             dition, the number of private industry in-
   The NACOSH charter expires in 2012.
                                             jury and illness cases reported nationwide
The OSHA press release is available at
                                             in 2009 that resulted in the need for time
www.osha.gov/pls/oshaweb/owadisp.show
                                             off from work, job transfer, or restriction
_document?p_table=NEWS_RELEASES
                                             fell from 2.0 cases per 100 workers in
&p_id=18609.
                                             2008 to 1.8 cases in 2009.
                                                 The manufacturing industry reported a
                                             23 percent drop in cases from 2008 to
ENFORCEMENT
                                             2009—the largest year-to-year decrease in
OSHA Cites U.S. Army Garrison for            injuries and illnesses since the North
Potential Chlorine Exposure                  American Industry Classification System
OSHA issued notices of unsafe and un-        (NAICS) was first published in 2003. The
healthy working conditions to the U.S.       construction industry also saw a signifi-
Army garrison at Fort                        cant decline in 2009 with its incidence
Riley, Kan., on Oct. 15                      rate dropping to 22 percent. The com-
after an inspection                          bined decrease in cases reported in these
found that workers at                        sectors make up 56 percent of the total
the garrison’s water                         private industry decline in 2009 injury
treatment plant were                         and illnesses.
consistently exposed                             For more information, visit
to hazards that in-                          www.bls.gov/news.release/archives/osh_1
volved a potentially                         0212010.pdf.
dangerous release of


                                                                                                       Circle Fax-back Card No. 8

                                                                                           December 2010 I The Synergist            15
DEPARTMENT | NEWSWATCH

[From: 15]
and personal care facilities. The plan ex-             data_General_Facts/Crowd_Control.html,         standable, and more useful to our part-
amines various factors such as the num-                provides employers with recommended            ners as a tool for protecting workers’
ber of injury and illness cases, the                   elements for crowd management plans.           health,” said NIOSH Director John
number of days a worker must stay away                    “Crowd-related injuries during special      Howard. “Although the U.S. has made
from work, and the number of employ-                   retail sales and promotional events have       great progress in controlling work-related
ees who received job transfers or work                 increased during recent years,” Michaels       lead exposures since the enactment of
restrictions because of injury or illness.             told the CEOs. “Many of these incidents        the Occupational Safety and Health Act,
   More information about SST-10 is                    can be prevented by adopting a crowd           we must remain vigilant in recognizing
available at www.osha.gov/OshDoc/                      management plan, and this fact sheet           and addressing this occupational hazard.”
Directive_pdf/CPL_02_10-06.pdf.                        provides retail employers with guidelines          Initiated in 1987, the ABLES program
                                                       for avoiding injuries during the holiday       is intended to build states’ capacity to ini-
CROWD CONTROL                                          shopping season.”                              tiate, expand, or improve adult blood lead
                                                          In 2008, a worker was trampled to           surveillance programs. More information
OSHA Urges Major Retailers to Take                     death while a mob of shoppers rushed           on ABLES is available at www.cdc.
Worker Safety Precautions                              through the doors of a large store to take     gov/niosh/topics/ABLES/ables.html.
In early November, Assistant Secretary                 advantage of a Black Friday sales event.
of Labor David Michaels sent a letter to                  For a copy of the letter sent to the CEOs   EMERGENCY MANAGEMENT
the CEOs of 14 major retail companies—                 and a list of the retailers they represent,
including Kohl’s, Sears, Target and                    visit www.osha.gov/ooc/blackfriday             FEMA Encourages Emergency
Macy’s—urging them to take precautions                 letter.pdf.                                    Managers to Plan for Entire
to prevent worker injuries during Black                                                               Community
Friday and other holiday sales events.                 LEAD
                                                                                                      In an address to emergency managers in
Enclosed with the letter was the OSHA                                                                 San Antonio, Texas, Federal Emergency
fact sheet, “Crowd Management Safety                   NIOSH Releases Online Lead                     Management Agency (FEMA) Adminis-
Tips for Retailers.” The fact sheet, avail-            Database                                       trator Craig Fugate encouraged attendees
able at https://www.osha.gov/OshDoc/                   A new online resource released by              to consider the capabilities and needs of
                                                       NIOSH in November will help users iden-        the entire community, including people
                                                       tify, monitor, and address harmful over-       with disabilities and children, when
                                                       exposures to lead, the agency stated in a      planning for disasters.
                                                       press release. The web page provides
                                                       data on cases of elevated levels of lead
                                                       in the blood of adults, and trends in
     www.RAECO.com
                                                       those cases over time.
     Daily, weekly, and
     monthly rentals.
                                                          Intended primarily for use by occupa-
                                                       tional and environmental health profes-
                                                       sionals and researchers, the web page
                                                       allows users to customize reports by
                                                       year, U.S. state, age group, type of expo-
                                                       sure, industry sector, and gender. The            “Considering the needs of all members
                                                       data are drawn from the NIOSH-funded           of our community and planning for
                                                       Adult Blood Lead Epidemiology and Sur-         worst case scenarios is exactly why we
                                                       veillance (ABLES) program. Exposure in-        need a strong emergency management
                                                       formation from 2002 through 2008 is            team—a team that FEMA is only one
 Your one-stop rental source for...                    available for 40 states.                       member of,” Fugate told his audience at
             Respirator t testing systems                 The new web page can be found at            the 58th Annual International Associa-
        Air monitoring and sampling pumps
          Combustion e ciency analyzers
                                                                                                      tion of Emergency Managers Conference.
            Gas detection and monitoring                                                              “We know government can’t do it
        HVAC and ventilation test instruments                                                         alone—many of the most innovative
            Indoor air quality monitoring                                                             ideas for how we can protect all mem-
                Particulate monitoring                                                                bers of our community from the impacts
         Sound and noise level monitoring                                                             of disasters will come from you.”
                   See our website for the full list                                                     Fugate then announced a FEMA-
                                                                                                      sponsored competition intended to gen-
          Save an automatic 5% when                                                                   erate ideas for ways that communities
          you rent at www.RAECO.com!                   wwwn.cdc.gov/niosh-survapps/ables/             can become better prepared for disas-
          Need help with your rentals?                 default.aspx.                                  ters. The winning idea will be featured
       Call 866-RENT-EHS (866-736-8347)                   “With this new web page, we are             on the agency website. For more infor-
                                                       pleased to make data from the ABLES            mation about the competition, visit
     New instrumentation catalog!
                                                       program more accessible, more under-           http://challenge.gov/fema.
     Get yours at www.RAECO.com
               Circle Fax-back Card No. 9

16              The Synergist I December 2010
NEWSWATCH | DEPARTMENT




ENFORCEMENT                                                                    IH Careers a Hot Topic in the News
MSHA Asks Court to Temporarily Close                             From Yahoo! to the Wall Street Journal, media outlets have been giv-
Kentucky Mine                                                    ing industrial hygiene and related professions a lot of attention lately:
On Nov. 3, MSHA filed a motion with the U.S. District
                                                                  • For its video series “Career Paths,” the Wall Street Journal online
Court for the Eastern District of Kentucky for a prelim-
                                                                    featured an interview with AIHA® member and EHS Director at
inary injunction against Freedom Energy Mining Co.’s
                                                                    Emilcott, Paula Kaufmann, CIH. The video, available at
Mine No. 1 in Pike County, Ky. This is the first time
                                                                    http://bit.ly/a5rNfW, shows Kaufmann performing a health and
MSHA has used its authority to take legal action of
                                                                    safety audit and discussing what motivates her in her career.
this nature. Freedom’s Mine No. 1 is owned by Massey
Energy Co., which also owns the Upper Big Branch                  • CNNMoney.com, in collaboration with PayScale.com, ranked envi-
mine in Montcoal, WVa., where 29 miners were killed                 ronmental health specialist as the 22nd best job in America with a
in an April 5 explosion.                                            28 percent 10-year job growth and a median salary of $71,000.
   In its brief, MSHA claims Freedom Energy has con-                Jobs on the list, which appeared in the November 2010 issue of
sistently failed to investigate and manage crucial ele-             Money magazine, are ranked by pay, job growth and quality of life.
ments of its mining operations, and                                 To view the list, go to http://bit.ly/9pjvhY.
cites four specific safety areas                                  • Investopedia, powered by Yahoo! Finance, listed IH as one of seven
where the mine hasn’t properly                                      jobs employers are desperate to fill. Investopedia reports that IH
protected its workers. According to                                 jobs are expected to increase by 14 percent within the next eight
MSHA, Freedom Energy neglected                                      years. Visit http://yhoo.it/b6FvDQ to read the article.
to clear the mine of excessive accu-
mulations of coal dust, failed to                                  Have you seen industrial hygiene in the news? If so, let The
maintain an adequate roof control                                Synergist know by e-mailing synergist@aiha.org.
plan, failed to test and maintain
the safety of electrical equipment to guard against

                                      [Continued: 18]




                                                           Circle Fax-back Card No. 10

                                                                                                December 2010 I The Synergist             17
DEPARTMENT | NEWSWATCH

[From: 17]
fires or explosions, and neglected to                                                           The guidance does not define or re-
properly ventilate the mine of hazardous                                                     quire a specific control option for a par-
and explosive gases. Freedom Energy                                                          ticular type of source because BACT is
Mine No. 1 is located in a coal seam that                                                    determined on a case-by-case basis. In-
emits excessive amounts of methane and                                                       stead, the guidance and resources pro-
is prone to roof collapses—there have                                                        vide the basic information that permit
been six major roof falls in the mine                                                        writers and applicants need to address
since Aug. 11, 2010.                                                                         GHGs. The guidance also provides exam-
    MSHA issued 1,952 citations and 81         local air permitting authorities identify     ples of how permitting requirements
orders during eight standard inspections       cost-effective pollution reduction op-        could apply.
between July 2008 and July 2010. If the        tions for greenhouse gases (GHGs) under          In January 2011, industries that are
court grants MSHA’s motion, Freedom            the Clean Air Act, the agency stated in a     large emitters of GHGs, and are planning
Energy will be forced to temporarily close     press release.                                to build new facilities or make major
its mine until it fixes all dangerous condi-      EPA recommends that permitting au-         modifications to existing ones, will work
tions and institutes an MSHA-approved          thorities use the best available control      with permitting authorities to identify
health and safety management program.          technology (BACT) process to look at all      and implement BACT to minimize their
    To read the MSHA press release, visit      available emission reduction options for      GHGs. This includes the nation’s largest
www.msha.gov/MEDIA/PRESS/2010/NR1              GHGs. After taking into account technical     GHG emitters, such as power plants, re-
01103.pdf.                                     feasibility, cost and other economic, envi-   fineries and cement production facilities.
                                               ronmental and energy considerations,          Emissions from small sources, such as
GREENHOUSE GASES                               permitting authorities should narrow the      farms and restaurants, are not covered
                                               options and select the best one. EPA an-      by these GHG permitting requirements.
EPA Issues Pollution Permitting                ticipates that, in most cases, this process      Information about EPA’s guidance is
Guidance                                       will show that the most cost effective way    available from www.epa.gov/nsr/ghg
New tools made available by EPA in             for industry to reduce GHG emissions will     permitting.html.
November are intended to help state and        be through energy efficiency.

                                                                                       In Brief
                                                John Funk, a former Nevada Test Site worker who helped lead the fight for com-
                                                pensation for work-related illnesses, died Oct. 13 of complications from chronic
                                                obstructive pulmonary disease, the Las Vegas Review-Journal reported. (“Funk, ad-
                                                vocate for ex-test site workers, dies at 69,” Oct. 29.)
                                                Indiana OSHA was investigating the death of a 20-year-old student at the Univer-
                                                sity of Notre Dame who died while filming a practice of the Notre Dame football
                                                team when the scissor lift he was in tipped over from high winds. (“Declan Sullivan,
                                                Notre Dame videographer dies in accident, OSHA launches probe,” Washington Post.)
                                                The makers of Brazilian Blowout, a chemical hair-straightening treatment, stated
                                                in November that they would initiate legal action against Oregon OSHA following
                                                an agency alert that said the treatment contains dangerous amounts of formalde-
                                                hyde. (“Brazilian Blowout Formally Initiates Legal Proceedings Against Oregon
                                                OSHA,” www.sys-con.com.)
                                                Illinois Senator Dick Durbin called for an EPA probe of toxic diesel pollution in
                                                Chicago’s two major rail stations and inside the cars that carry commuters. In No-
                                                vember, the Chicago Tribune reported that riders on the city’s Metra transit system
                                                were exposed to levels of diesel soot up to 72 times higher than on the streets out-
                                                side the system. (“Metra riders subjected to high amounts of diesel soot,”
                                                www.chicagotribune.com.)
                                                Britain’s Health and Safety Executive (HSE) reports 152 worker deaths in 2009-
                                                2010, a rate of 0.5 fatalities per 100,000 workers. (“The Health and Safety Executive
                                                Statistics 2009/10,” www.hse.gov.uk.)
                                                Employees of Ames Laboratory from 1955 through 1960 who developed cancer
                                                were granted compensation by the U.S. Advisory Board on Radiation and Worker
                                                Health. Ames Lab, a Department of Energy facility, was the site of secret research
                                                with radioactive materials, including uranium. (“Ames Lab uranium cause of cancer
                                                in workers; compensation claims approved,” Iowa State Daily.)


          Circle Fax-back Card No. 11

18         The Synergist I December 2010
®




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Insight
     EXPOSURE ASSESSMENT         I   RISK ASSESSMENT




EXPOSURE ASSESSMENT


Time for Modeling
Toward a Culture Change for Industrial Hygienists
BY STEVEN D. JAHN




On a recent trip to my parent’s home in Connecticut, I received a     “safe” exposures from our considered “professional judgment”
book from my Dad to read on my way back to South Carolina.            are grossly in error. The second is laziness. We should be chas-
The book contained an appropriate reference for gauging our           ing an effective occupational health program with our best ef-
progress in the use of modeling tools in exposure assessment.         fort, but we cannot muster the energy. The majority of modeling
   Many of us learned our craft from graduate schools and cor-        is done by a handful of practitioners, and often for litigation or
porate organizations that expected a professional technical de-       regulatory reasons.
fense of judgments made to protect worker health. We were
expected to ferret out hazards that mattered and defend the ex-       Attitude
penditure of dollars toward controls (whether engineering or ad-      So how can we spark a return to our foundation of decision
ministrative). Demonstrating the “adequacy” of that posture was       making, exposure assessment? By making a professional com-
left to the ethics of the individual—and of the corporate auditors    mitment to learning and using models. The second edition of
who looked at the work (and possibly wrote the procedures and         Mathematical Models for Estimating Occupational Exposure to
trained us as well).                                                  Chemicals is ready to guide your schooling. Join us in moving
   If this description reflects your experience, then your attitude   this critical tool to the forefront of exposure assessment.
may have been as mine was: I declared myself to be a profes-             And that book my Dad gave me? It was titled, Do the Right
sional, short on time to document hazards that didn’t exist, and      Thing.
long on ethics.
   If you have read The Synergist or the Journal of Occupational      Steven D. Jahn, CIH, is a senior IH technical advisor in Aiken, S.C. He can be
and Environmental Health for any length of time, you recognize        reached at steven.jahn@srs.gov or (803) 557-3828.
that Tom Armstrong and Mike Jayjock have lobbied for years
for a transparent defense of our professional judgments through
modeling. Yet even today, exposure modeling is rarely used. This
resistance to modeling is cultural; changing a culture is slow
                                                                       Resource
work, and can be measured through what I call the three A’s: at-
                                                                       1. Logan, P.W., G. Ramachandran, J.R. Mulhausen, and
titude, atmosphere, and acceptance.                                       P. Hewett: “Occupational exposure decisions: Can limited
                                                                          data interpretation training help improve accuracy?”
Atmosphere                                                                Annals of Occupational Hygiene, 53(4):311–324 (2009).
In 1980, OSHA was ten years in existence and I was an indus-
trial hygienist in training. Our professional emphasis was on
monitoring data, not models. (By the way, we still don’t have an
exposure assessment standard to drive the right monitoring pri-        Guidance for Exposure Modeling
ority.) However, most of our judgments are rendered with no
                                                                       The second edition of AIHA’s Mathematical Models for Esti-
sampling data.1 It is the rare occasion when statistically valid
                                                                       mating Occupational Exposure to Chemicals, edited by
data populations drive exposure assessment decisions.                  Charles B. Keil, Catherine E. Simmons, and T. Renee Anthony,
                                                                       was released in 2009. Members can purchase this resource at
Acceptance                                                             a discount of nearly 25 percent from the nonmember price.
There are two reasons why our profession has not yet accepted          Go to www.aiha.org/marketplace.
exposure modeling. The first is fear of learning that supposedly


20         The Synergist I December 2010
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DEPARTMENT | INSIGHT



                         RISK ASSESSMENT


                         Crossing a Threshold
                         Do “Zero-Risk” Exposures Exist?
                         BY FRANK MIRER




Do observations of chemical hazards at high exposure levels
predict risk at much lower levels? Or are there reliably “safe”
(that is, zero-risk) doses or exposure levels for most chemicals
other than carcinogens? To lay down the gauntlet, this column
argues that the concept of a “threshold” in a population violates
the principle of the exposure-response relationship. I agree
there are population doses with minimal risk, perhaps practical
thresholds for concern. But assuming a threshold assumes
there is an exposure region where increasing exposure doesn’t
increase risk.
    Our jobs as practitioners include communicating the risk
of a chemical exposure at levels well below those where a
hazard has been identified. Paracelsians fondly say that
“everything” is a poison at some dose, as a way soft-soaping
people exposed to a chemical already shown to a be a poison.
(I think Paracelsus used that argument to defend using mercury
as a medicine, based on an alchemical theory; probably he
said or wrote it in Latin.) Opining about causation where one
person among a larger group of similarly exposed individuals
becomes ill is another side of that coin. In some situations,
the illness is clearly associated with exposure to the chemical
in some setting; in others, past evidence of association may
be shaky.
    As practitioners, we rely mostly on authorities like govern-    Defining “Zero-Risk”
ment or scientific organizations to tell us the level of exposure   We are taught that all chemicals exhibit an exposure-response
where there’s a concern or probability of adverse effect. Since     relationship: the lower the dose, the lower the risk. Is there a
OSHA and NIOSH have done little in the past decade (or more)        threshold—that is, the upper bound of zero-risk doses? A
to bring exposure rules or recommendations in line with             threshold dose implies a dose region in which there is no expo-
emerging science, the main sources of such data are the EPA         sure-response relationship—within this region, increasing the
Integrated Risk Information System (IRIS) reference doses and       dose carries no increased risk because the risk is zero. This re-
concentrations (www.epa.gov/iris/) and the Agency for Toxic         gion is a biological black hole: dose goes in, but no response
Substances and Disease Registry (ATSDR) minimal risk levels         comes out.
(MRLs) for hazardous substances (www.atsdr.cdc.gov/mrls/               What evidence is there for a threshold? Proving the thresh-
index.html).                                                        old (in a population exposure-response relationship) is as diffi-
    I tell my students to go to IRIS and ATSDR whenever they        cult as proving any negative. I teach the concept of “Limit of
have an identified chemical exposure level to evaluate. IRIS        Direct Observation” (LODO)—the power of various methods to
calculates a unit cancer risk for carcinogens, based on linear      see the toxic potential of an exposure, if it were there. The
low-dose extrapolation, and generates reference doses and con-      LODO for laboratory studies is a risk of about 1 in 10 against a
centrations for non-cancer endpoints by applying uncertainty        zero background, the risk at the NOAEL or the benchmark dose.
factors to a no-observed adverse effect level (NOAEL) as a point    A background risk in control animals—for example, liver cancer
of departure. Some of these values are aggressive (5 mg/m3 for      in mice—moves the LODO upward. Some special designs (dis-
toluene), and some are very aggressive (0.1 mg/m3 for xylenes).     cussed below) might do a little better. (Remember that the
This column provides arguments for applying these aggressive        Supreme Court-derived border of “significant risk” is 1 in 1,000,
limits in the occupational setting.                                 or 0.1 percent.)


22         The Synergist I December 2010
INSIGHT | DEPARTMENT



    For studies in people, the LODO is the population rate of the     Important laboratory (and possibly human) carcinogens such as
target condition. The population rate of lung cancer in Ameri-        perchloroethylene (see “Percs at the National Academy” in the
can men is about 5 percent, so the LODO is whatever excess is         May 2010 Synergist) have not been shown to cause mutations
convincingly exposure-related. Maybe a 6 percent risk would           in short-term bioassays.
be statistically significant, but it would be difficult to get this      Maybe the most prominent and troubling “non-genotoxic”
accepted for hazard determination in a single study. Epidemiol-       carcinogen is dioxin. The consensus is that dioxin acts by binding
ogy can be more sensitive to elevated risks than laboratory           to the aryl hydrocarbon receptor (AhR). This interaction leads to
studies, but has many other barriers and obstacles.                   effects on a host of organ systems—immune, reproductive—and at
    Plenty of known human carcinogens—like sulfuric acid mist—        very low levels of exposure. AhR was not known when I was a
are unregulated even after direct observation. But, at 10 percent     real toxicologist back in the 1970s. EPA’s interminable update of
excess, we are extending knowledge below the LODO—that is,            the risk assessment for dioxin—the last draft went from EPA to the
laboratory studies cannot confirm that a risk is less than 1 in 10.   National Academy of Sciences in 2004—was sent back with com-
It’s like the dark side of the moon before the Apollo missions—       ments in 2006; EPA’s most recent response was released in May
we knew it was there, but hadn’t seen it.                             2010. EPA found low-dose risk for non-cancer endpoints as well
    Sometimes we get a window to test high-to-low-dose conti-         as cancer (see http://cfpub.epa.gov/ncea/CFM/nceaQFind.cfm?
nuity of risk. Environmental tobacco smoke is classified as           keyword=Dioxin). Honestly, the hundreds of pages, dozens of
“known to be carcinogenic to humans.” I voted for this classifi-      calculations, and, I assume, hundreds of references were too
cation in the National Toxicology Program (NTP) Report on Car-        much for me to digest.
cinogens sometime around the year 2000. This determination is            Every two years the Institute of Medicine, by law, updates
based on multiple epidemiologic studies in people, mostly com-        the list of conditions suffered by veterans exposed to Agent Or-
paring lung cancer rates among non-smoking spouses of smok-           ange and presumably caused by dioxin. Vietnam veterans who
ers with those of non-smoking spouses of non-smokers. The             suffer these diseases get compensation. Many organ systems are
lower rate of lung cancer among non-smokers extended the              implicated beyond cancers, including diabetes and nervous sys-
LODO downward. Cigarette smoke is a very low-potency car-             tem disorders (see http://books.nap.edu/openbook.php?record
cinogen (µg per µg), and the exposure gradient between direct         _id=12662). The important point is that low-dose effects for
and environmental exposures depends on which component of             non-cancer endpoints are prominent in the risk assessment
smoke is considered and which environmental exposure levels           based heavily on laboratory results and are also found in the
are assumed for the studies. But it could be 1,000-fold.              assessment of people with dioxin exposure.
    The gradient between occupational and take-home asbestos
levels also must be very large, so family mesotheliomas also          Acceptable Risk
provide evidence for high-to-low-dose continuity, and therefore       There’s no doubt that a “significant” risk (in occupational
lack of a threshold. The consensus is that the risk of cancer         terms) persists at the NOAEL, whether cancer risk or other. The
from ionizing radiation is also present at low doses, although        risk assessment task includes extrapolating known effects into
there are still deniers and advocates of the view that low doses      the dose region where direct observation is not feasible. The
are good for you (radiation hormesis).                                risk management tasks include deciding an acceptable risk. It
                                                                      might be useful to convert the extrapolation factors now used
Mega-Mouse and Mega-Rat                                               by EPA to calculate the reference concentrations in IRIS to risk
In the mid-1970s, the “mega-mouse” study was planned to con-          rates—I think the EPA benchmark dose software will actually do
firm or deny a threshold. Part of the Pine Bluff Arsenal, a bio-      this. The distance of extrapolation from the point of departure
logical and chemical warfare facility in Arkansas, was                dose to occupational levels is usually many factors of 10 less
reconfigured as the National Center for Toxicological Research,       than those in the general environment. The task is feasible, and
which housed the study. The agent chosen was acetylaminoflu-          it needs to be accomplished. Practitioners waiting for authorita-
orene, an amine to which few humans might be exposed. Here            tive results can look up the IRIS RfC, multiply by 3 to account
is the abstract of an early mega-mouse report:                        for 24/7/365 exposures compared with occupational, and they
Although bladder neoplasms exhibited a minimum effect level
                                                                      would be in the ballpark.
(or a nonlinear response) for specific conditions, the total re-
sults were consistent with a “no threshold concept.” The late-        Franklin Mirer, PhD, CIH, is a professor in the Environmental and Occupational
                                                                      Health Sciences Urban Public Health Program at Hunter College School of Health
appearing liver neoplasms displayed a nearly linear-type
                                                                      Sciences in New York. He can be reached at (212) 481-7651 or
response that extrapolated directly to zero dose.1                    fmirer@hunter.cuny.edu.
   A similar mega-rat study in England produced similar re-
sults. Subsequent reinterpretations—by industry-associated sci-        Resource
entists—have claimed evidence for a threshold. Overall, the
paradigm-testing experiment was like the tree that burned in           1. Farmer, J.H., D.W. Gaylor, and W.G. Sheldon: “Effects of
                                                                          Dose and Time in a Long-term, Low-dose Carcinogenic
the forest with no one to smell it. Did it give off smoke?
                                                                          Study.” J Environ Pathol Toxicol 3(3 Spec No):17–34 (1980).
   The next stage of the debate was to concede the plausibility
of linear low-dose extrapolation for “genotoxic” carcinogens
but to argue a threshold for agents that did not cause mutations
                                                                                                CONNECT for CREDIT
in short-term bioassays but did cause cancer in whole animals.                              www.aiha.org/syntestseries


                                                                                                 December 2010 I The Synergist                   23
FEATURE | Extreme Makeovers




EXTREME
 MAKEOVERS
         Tips for Improving EHS Graphics

BY ED RUTKOWSKI




B
Bob Emery talks about data the
way a novelist might discuss verbs.
Currently vice president for Safety,
Health, Environment and Risk
Management at the University of
Texas (UT) Health Science Center at
Houston, Emery has worked in
OEHS for 25 years, and he’s certain
that the main reason why his OEHS
colleagues struggle to win the ap-
                                             campus, one of the university’s major
                                             buildings flooded, rendering the bottom
                                             floor unusable. In the days following re-
                                             occupation of the upper floors, Emery’s
                                             team at the Health Science Center cre-
                                             ated graphs of indoor air quality data
                                             and posted them by the elevators, where
                                             University employees were sure to notice
                                             them. Instead of simply listing the data,
                                             the graphs clearly showed that air qual-
                                             ity measurements were within ASHRAE
                                             guidelines for IAQ.
                                                                                            information. His lectures incorporate the
                                                                                            ideas of American statisticians Edward
                                                                                            Tufte and John Tukey, who have made
                                                                                            important contributions to the field of in-
                                                                                            formation design, and he often presents
                                                                                            on the topic at conferences.
                                                                                               Emery’s dual role allows him to chal-
                                                                                            lenge his students with examples straight
                                                                                            from his inbox. His assignments require
                                                                                            students to create new presentations of
                                                                                            existing data, and some of their
                                                                                            makeovers are startlingly good. (A stu-
proval of management is a seem-                 “When they were waiting to go to            dent’s re-creation of BP exposure moni-
                                             their floor, they could actually see what      toring data from the Gulf oil spill appears
ingly innate difficulty making               the relative humidity levels were, what        in Figure 1.)
data—the dry essence of exposure             the temperature was—and they could see            The Synergist recently spoke with
monitoring—come alive.                       this within the context of these red lines     Emery about data presentation. Excerpts
   “We function largely in the field of      that showed the ASHRAE recommenda-             from this discussion appear on the fol-
prevention, so on a good day, nothing        tions,” Emery recalls. “We had hardly any      lowing pages.
happens,” Emery says. “The problem is        indoor air quality complaints, I believe
that we’ve got to get better at explaining   largely because people could see the data      The Synergist: If you were to make a
to various stakeholders all of the work      within the context of the reference lines.”    broad generalization, how would you
that went on behind the scenes to make          For Emery, data is more than raw            characterize most OEHS professionals’
nothing happen. And part and parcel of       numbers; it’s part of a narrative. When        skills in data presentation?
that is showing data.”                       his employees show him a problematic           Bob Emery: I'm struggling to find a po-
   The event that crystallized the impor-    graph, he’ll say, “You’ve got a good story     lite term for “atrocious.” I don’t mean
tance of data presentation for Emery was     to tell, but this sure ain’t telling it.” He   that in a bad way; it’s just sometimes
Tropical Storm Allison, which dumped         has ample opportunity to share this judg-      we’re so focused on the trees that we
35 inches of rain on Houston in June         ment with UT students, too: 20 percent of      miss the forest. And that’s really what
2001 and caused $5 billion worth of          his appointment is dedicated to teaching       drove my interest in graphics, because in
damage across Texas. On UT’s Houston         a class on communicating public health         my field, I see confusing graphics time


24         The Synergist I December 2010
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Synergist201012 dl

  • 1.
  • 2. THE Synergist ® 12/10 www.aiha.org Improve Your Graphics Does your data show the forest or the trees? 8 Building IH Capacity in the U.S. 22 Do “Zero-Risk” Exposures Exist? 27 ISO’s Social Responsibility Standard 29 The Business Case for OHS Databases
  • 3.
  • 5. Synergist ® THE Features 24 Extreme Makeovers A longtime EHS pro shares simple tips for making your data come alive. By Ed Rutkowski 27 Contentious Consensus Input from a diverse group of stakeholders will add to the credibility of ISO’s new standard on social responsibility. By Jeffrey Hogue 29 Streamlined Management How to build a business case for OHS databases. By Monica Melkonian 24 27 4 The Synergist I December 2010 29
  • 7. ® THE Synergist Volume 21 I Number 11 Columns & Departments Editor in Chief Constance Paradise, CAE: cparadise@aiha.org Managing Editor Ed Rutkowski: erutkowski@aiha.org Assistant Editor Brooke Morris: bmorris@aiha.org Senior Manager, Periodicals and Technology James Myers: jmyers@aiha.org Creative Services Associate/Designer Billy Stryker: bstryker@aiha.org Advertising Representative 8 President’s Message Network Media Partners Building Industrial Hygiene Ben Ledyard: bledyard@networkmediapartners.com Capacity in the United States By Michael T. Brandt Executive Director Peter J. O’Neil, CAE: poneil@aiha.org 10 Letters The Synergist ® is a copyrighted publication of the American Revisiting the Haiti Earthquake Industrial Hygiene Association, 2700 Prosperity Ave., Suite 250, Fairfax, VA 22031; (703) 849-8888; e-mail synergist@ 12 NewsWatch aiha.org. No part of The Synergist may be reprinted without the express written consent of AIHA. Submission of articles OEHS AND INDUSTRY NEWS or letters to the editor are welcome, but AIHA and The Syn- ergist will determine what to publish and reserve the right 20 Insight: Exposure Assessment to edit all submissions for content, style, length and clarity. The Synergist (USPS #009-332) is published monthly ex- Time for Modeling cept a combined June/July issue by the American Industrial By Steven D. Jahn Hygiene Association, 2700 Prosperity Ave., Suite 250, Fairfax, VA 22031 for $50 per year for members; nonmembers may 22 Insight: Risk Assessment subscribe for $275/yr. International nonmembers may subscribe for $375/yr (U.S. funds). Periodicals postage paid at Fairfax, Crossing a Threshold Virginia, and additional mailing offices. POSTMASTER: Send By Frank Mirer address changes to The Synergist, American Industrial Hygiene Association, Attn: Customer Service, 2700 Prosperity Ave., Suite 250, Fairfax, VA 22031. ISSN 10667660. 32 Community Publications Mail Agreement No. 40039445. Return AIHA NEWS undeliverable Canadian addresses to PO Box 503, RPO West Beaver Creek, Richmond Hill ON L4B 4R6. 35 Opportunities Editorial Advisory Board Members EDUCATIONAL EVENTS FOR Jeff Behar, California Institute of Technology OEHS PROFESSIONALS Wendell Britnell, LMI Patricia Crawford, Consultant 36 Product Features M. Cathy Fehrenbacher, U.S. EPA Don Garvey, 3M Co. Stephen Hemperly, Hitachi GST 37 Advertisers’ Index/ John Mazur, MACTEC Inc. Synergist Fax-Back Card Hank Muranko, Muranko & Associates Doris Reid, Saxe Colman Consulting Group 38 Introductions 12 John Rekus, John F. Rekus & Associates Ltd. COMING IN JANUARY I Wood-dust Exposures I Survey of OEHS Professionals I Smart Phones: Data Security and Privacy Concerns The Synergist’s mission is to provide AIHA members with news and information about the occupational and environmental health and safety fields and the industrial hygiene profession. The Synergist focuses on industry trends and news, government and regulatory activities, key issues facing the profession, appropriate technical information and news on association events and activities. The Synergist’s objective is to present information that is newsworthy and of general interest in industrial hygiene. Opinions, claims, conclusions and positions expressed in this publication are the authors’ or persons’ quoted and do not necessarily reflect the opinions of the editors, AIHA or The Synergist. 6 The Synergist I December 2010
  • 9. COLUMN | PRESIDENT’S MESSAGE President’s Message Building Industrial Hygiene Capacity in the United States BY MICHAEL T. BRANDT, AIHA® PRESIDENT We are well acquainted with the chal- Impact on AIHA their lesson plans to demonstrate how lenge of replacing current industrial hy- The report’s findings are both alarming science and math are used to solve gienists as they retire. In fact, other and relevant to AIHA. Who will be IHs crimes, remediate disasters such as Katrina, science, technology, engineering, and in the future? How will they be re- protect and rescue workers such as the medical (STEM) professions are experi- cruited? Where can we find qualified Chilean miners, clean up oil spills, and encing the same challenge and searching candidates? Will there be enough quali- prevent accidents. for ways to counter the following trends fied and competent IH practitioners? While K-12 education in America is a in U.S. education: The report contends that if teachers national concern, our system of education are better qualified to teach science and consists of 14,000 local school systems. • K-12 education lags behind that of math, then the number of students quali- Each of us lives in a community where other developed nations, despite a fied to enter STEM fields will increase. our children attend school. Solving this higher cost per student than any other As AIHA members, we need to ask our- problem begins in our communities. Solv- OECD (Organization for Economic Co- selves, “What have we done to improve ing this problem begins with each of us! operation and Development) country. STEM education in our communities?” If we are to achieve our mission of • Junior and senior high school stu- Opportunities to make a difference are “Creating knowledge to protect worker dents are inadequately prepared in plentiful. Personally, I have volunteered health,” we need to ensure that ours is a math and science. at three graduate schools to teach envi- vibrant profession that attracts well quali- • 78 percent of high school graduates ronmental and occupational health, in- fied students and early-career profession- do not meet the readiness benchmark dustrial hygiene, finance and other als. Sharing our experiences with young levels for one or more entry-level col- courses. I have also visited middle and minds that are searching for purpose is a lege courses in math, science, reading, high schools in my community to intro- good start. If each of our 10,000 members and English. duce students to industrial hygiene and stimulated just one student to study math generate interest in math and science. and science throughout high school and • Fewer college students are receiving AIHA National has invested member then college, we would increase the talent undergraduate degrees in science or equity over the past ten years to recruit pool for all STEM fields. I encourage each engineering. and mentor early-career IHs. But our of you to get involved with your local new memberships are not keeping pace schools either individually or as a local These statistics are found in the re- with retirements. The report from NAS section with an action plan. Change begins cently released National Academy of is further confirmation that unless we with the first step. Science (NAS) report “Rising Above the reverse current trends, there won’t be Gathering Storm, Revisited.” (A free PDF enough qualified IHs to replace retiring Michael T. Brandt, DrPH, CIH, PMP, is technical chief of the report is available from www.nap. of staff for Operations at Los Alamos National Labo- IHs, let alone grow the profession. edu.) This update of the original 2005 ratory in Los Alamos, N.M. He can be reached at study assesses the principal ingredients (505) 667-1228 or mtbrandt@lanl.gov. of innovation and competitiveness— Local Outreach I challenge each local section to reach Resources for Outreach knowledge capital and human capital. out to middle- and high-school teachers. NAS research shows that funding of to Students Offer to help them generate enduring in- R&D as a percentage of GDP has de- terest in the application of scientific Visit the AIHA website at clined more than 60 percent in the past www.aiha.org/insideaiha/students/ principles to solve real-world problems. 40 years, and only 4.5 percent of Ameri- Pages/StudentOutreachMaterials. Since the average K-12 student spends can college students are earning degrees aspx for information related to four hours each day watching TV, we in engineering. conducting outreach to students. could help teachers incorporate IH into 8 The Synergist I December 2010
  • 11. COLUMN | LETTERS Lettters Revisiting the Haiti Earthquake To the Editor: Hornsby-Myers responds: This is in response to the article “The Next Day, Everything Was Flat” (October I appreciate the comments of LTC Goff issue) in which Managing Editor Ed Rutkowski interviews Jennifer Hornsby-Myers and MAJ Carter of the U.S. Air Force, from NIOSH. Ms. Hornsby-Myers deployed to Haiti with the CDC as a public health and I also appreciate the opportunity to liaison to Joint Task Force-Haiti (JTF-H). While we laud her work, she doesn’t have clarify an off-the-cuff general com- all her facts straight, specifically regarding the military’s capability to provide pub- ment in my Synergist interview that lic health support. While she is correct in saying public health is not the military’s prompted the letter concerning my de- primary mission, she completely misses the mark in saying the military doesn’t ployment to Haiti. I certainly did not have many public health assets. The Air Force takes great pride in its robust public intend to imply that the Department of health, environmental health and industrial hygiene assets. JTF-Haiti was no dif- Defense does not have public health ferent with this support. assets. My comment was intended to When Air Force Special Operations Command personnel landed in Port-au- delineate between the overall mission Prince on Jan. 13, 2010, there was a public health officer and preventive-medicine of the DoD and the CDC, not the spe- physician on the very first plane as part of the team of command and control, cific assets of each group. From my combat controllers, and para-rescue personnel to open up the airport and begin personal experience during my deploy- search and rescue operations. On Jan. 14, 2010, there was an Air Force industrial ment, all of the services that make up hygiene technician on the ground. The three made up what we call a Special the DoD did an outstanding job of sav- Operations Forces Medical Augmentation team and immediately began vector ing lives and providing security post- and rodent control, drinking water sampling, hazardous noise characterizations, earthquake—as did all of my colleagues heat stress monitoring, proper hazardous waste and used oil storage work. in the U.S. Public Health Service. Within a week, and then a month, as more conventional forces arrived (called The intended message of this part of Global Reach Laydown and Preventive Aerospace Medicine teams), more public the article was to highlight the valu- health and industrial hygiene assets came with the rescue personnel and surgeons. able partnership that existed between With them came more air, water, noise, and vector sampling equipment, with the CDC and the DoD through the JTF- which they were very busy evaluating and providing advice to JTF leadership on H (Joint Task Force-Haiti). This was the risk control measures. first time, to my knowledge, that CDC As a force within the Air Force, there are on average 10–20 Public Health Air- had a liaison to a JTF during a foreign men, 10–20 environmental health/industrial hygiene Airmen (the Air Force calls disaster. It proved to be a very benefi- them Bioenvironmental Engineers), and 2–3 physicians trained in occupational/ cial relationship not only for the CDC preventive medicine at each base around the world, and a smaller number at each and the DoD but for the overall mis- deployed location in the Middle East and South Asia supporting our operations. sion of providing vital assistance to the While we can’t speak for the Army, Navy, or Marines (and we hope they comment Haitians who were (and are) suffering on this article), we can say without a doubt that the Air Force has many robust so greatly. I sincerely hope that the public health, environmental health, industrial hygiene, and preventive medicine Haitian relief effort will be a model for assets, both at our “home bases” and our deployed locations. any future foreign disasters, including a CDC Liaison to the JTF. Lt. Col. Philip Goff, CIH, Command Bioenvironmental Engineer for Air Force Special Operations Command, who provided command oversight for JTF-Haiti Air CDR Jennifer Hornsby-Myers, MS, CIH Force preventive medicine forces. CDC Liaison to JTF-H United States Public Health Service Major Rebecca Carter, PhD, deputy flight commander of the 96th Aerospace Medi- CDC/NIOSH cine Squadron Bioenvironmental Engineering Flight, Eglin Air Force Base, Florida, who deployed to JTF-Haiti with a Preventive Aerospace Medicine Team. 10 The Synergist I December 2010
  • 12. The Occupational Environment: Its Evaluation, Control, and Management, 3rd Edition An essential core reference for OEHS practitioners, educators, and students, the newly revised 3rd edi- tion includes information on hazard recognition and evaluation, physical agents, program management, and more. Most chapters have been rewritten and updated to include the most current information available in a single OEHS reference. Volume 1 focuses on chemical aspects, air monitoring, and exposure and risk assessment strategies. Volume 2 includes content related to the physical hazards, control methods, and management aspects. Several new chapters have been added to cover nanotechnology, ethics, IH issues in construction, the AIHA Value Strategy business model, and more. Complete Set: BIHT10-566 ...............................Member Price: $229 ..............Nonmember Price: $309 Volume 1: BIHT10-765................................Member Price: $129 ..............Nonmember Price: $209 Volume 2: BIHT10-766................................Member Price: $129 ..............Nonmember Price: $209 Be among the first to pre-order this book. Visit www.aiha.org/market or call Customer Service at (703) 849-8888, Monday–Friday, 9 a.m.–5 p.m. ET. ® AIHA Publications—Reliable References for OEHS Professionals Globally
  • 13. SPECIAL TO THE DIGITAL EDITION THE Synergist ® Preparing for January 10/11 www.aiha.org Washington Insider By Aaron Trippler, Director, AIHA® Government Affairs The voters have spoken, and Washington is prepar- OSHA Reform ing for another session of a Congress that will look Under a Republican-controlled House, OSHA is unlikely much different from the one about to conclude. to receive additional authority to impose regulations on The ramifications of the midterm elections will affect employers. Republicans have hinted they are unwilling to legislative action in Congress and occupational health consider substantial changes to the way OSHA operates and safety activity at the agency level. At the very and have already announced there will be more oversight least, changes in legislative leadership will affect the of regulatory agencies. Of course, industry hopes the OHS agenda. House will go even further than simple oversight and stop several activities within OSHA. The following issues may come up for discussion during Leadership the new Congress: Leadership in the Senate will likely remain as is: Expect Mine Safety and Health. Republicans may sit down with Senator Tom Harkin to remain chairman of the Health, Democrats and work out a bill that would provide addi- Education, Labor and Pensions (HELP) Committee and tional health and safety measures in the mining industry. Senator Patty Murray to remain chairwoman of the sub- Whether this bill will go as far as the bill introduced in committee that oversees OSHA. Senator Mike Enzi is also 2010 is unclear. likely to continue as the Republican leader on the HELP Injury and Illness Prevention Program Rule. Industry Committee. may work with House leadership to stop OSHA’s efforts The House leadership will experience considerable to enact an injury and illness prevention program rule. change. Rep. George Miller is out as chairman of the The most obvious way to stop agency efforts is through House Education and Labor Committee, with Rep. John the appropriations process. Kline the likely successor. Who might chair the subcom- MSD 300 Log Addition. Industry will also work to enlist mittee with OSHA oversight has yet to be determined, the support of Republicans to stop OSHA from moving but Rep. Lynn Woolsey is out. forward on this proposal, which industry views as a “back The Synergist | December 2010 DE 1
  • 14. SPECIAL TO THE DIGITAL EDITION door” approach to ergonomics. However, adding an MSD on OSHA and its efforts to regulate employers. Both column on the OSHA 300 log has numerous supporters groups are probably wrong. In the last two years, no leg- who will argue that OSHA should be allowed to continue islation to address workplace health and safety was en- its efforts. acted, so it’s not like the Republicans have anything to repeal. And the Republicans will likely be unsuccessful in Voluntary Protection Program (VPP). Republicans may many attempts to limit agency oversight. work to enact legislation that would codify and perma- nently fund the Voluntary Protection Program. This ap- proach enjoyed bipartisan support in the previous session What about OSHA? of Congress. OSHA had hoped to convince Congress that the VPP should be user funded. Expect any OSHA appro- OSHA will continue to pursue its agenda, but this won’t priations measure to include continued funding for VPP. be quite as easy as before the election. Industry is much more empowered to oppose OSHA efforts and will at- NIOSH. What the new Republican leadership might do tempt to stop, or at least slow, agency activity. Most no- with NIOSH is unclear. While some Republicans believe tably, OSHA will have even more difficulty addressing these types of agencies need to be shut down, just as anything remotely related to ergonomics. The Injury and many recognize their value. AIHA® has been meeting Illness Prevention Program (I2P2) rule may also face with other stakeholders to discuss possible efforts to en- problems from industry, which has already approached sure that NIOSH is funded and protected. One possibility members of the House about stopping this program, is to have the Government Accountability Office study most likely through appropriations. the pros and cons of keeping NIOSH within the organiza- tional structure of the Centers for Disease Control and Agency activity on other issues will continue but likely at Prevention (CDC). AIHA believes there is support for such a slower pace. OSHA will have to consider whether an ac- a study within the GOP and within NIOSH. In a recent dis- tivity has a reasonable chance of success before it moves cussion, AIHA learned that CDC has appropriated nearly forward. Issues such as VPP, changing the on-site consul- $300 million of the NIOSH budget for CDC expenses over tation program, and updating the PELs will all be more the past 18 years. difficult to achieve. Appropriations. Republicans in the House will certainly attempt to control spending. Some possibilities include What about the States? cutting federal employment by 10 percent, federal dis- A considerable number of states saw a switch in party cretionary spending by $100 billion per year, and agency control of the governor’s office, and many of the state spending by 22 percent. Another possibility is to cap legislatures also saw a switch to the Republican party. It’s spending at 2008 levels. All of these actions will be con- hard to tell how this might impact occupational health sidered, but the Senate is unlikely to allow such drastic and safety in 2011. I expect states to continue to be more changes. inclined than the federal government to address specific However, Republicans may place language in many of the OHS issues. Look for the same involvement in the states appropriations bills that limits where the dollars may be on issues such as mold abatement, methamphetamine spent. For example, they could adopt an OSHA budget laboratories, Chinese drywall, and other issues that di- that prohibits spending money on advancing an injury and rectly impact workers and consumers. illness prevention program rule. Any threats to agency ac- tivity are likely to come from actions such as this. Aaron Trippler directs government affairs for more than 70 The bottom line: many stakeholders say the new Congress local sections and serves as AIHA’s chief liason with Congress will be devastating for occupational health and safety, and federal agencies. He can be reached at (703) 846-0730 or while many others predict that Congressional limitations atrippler@aiha.org. The Synergist | December 2010 DE 2
  • 15. NewsWatch OEHS NEWS I GOVERNMENT NEWS I INDUSTRY NEWS STANDARDS are issued only when they cost less than a hearing conservation program and PPE is ineffective. In the proposed amendment to ISO Releases Guidance Standard on Social Responsibility its noise enforcement policy, the agency intends to sanction the On Nov. 1, the highly anticipated ISO 26000:2010 standard, issuance of citations requiring the use of administrative and en- Guidance on Social Responsibility, was unveiled in Geneva, gineering controls when feasible as noted in the interpretation. Switzerland. The standard provides guidance to business and “Since 1983, when the current interpretation was in place, public sector organizations on social there has been a somewhat unrealistic reliance on hearing pro- responsibility concepts and imple- tection,” says AIHA® Noise Committee Chair Joe Cissna, CIH, mentation elements. MHS. “So we support OSHA for bringing engineering controls Development of ISO 26000:2010 more to the forefront. It follows the hierarchy of controls prin- lasted more than eight years. AIHA® ciple that underpins the industrial hygiene approach.” participated as a D-Liaison organiza- OSHA is accepting comments through Dec. 20, 2010. Com- tion, which enabled the association to ments can be submitted at www.regulations.gov, by mail, or by take part in the formal standard pro- fax to (202) 693-1648. Individuals who mail or deliver com- ceedings and contribute to the drafting ments must submit three copies to the OSHA Docket Office. process. Faxed submissions may not exceed 10 pages. Unlike other management interna- The OSHA proposal is available at tional standards, ISO 26000:2010 contains voluntary guidance, http://edocket.access.gpo.gov/2010/2010-26135.htm. To read not requirements, and is not intended for certification pur- OSHA’s press release, visit http://bit.ly/aVEKXo. poses. “The key purpose of the standard is to encourage organiza- RESEARCH tions to integrate social responsibility throughout their deci- sions and activities,” states Jeffrey Hogue, who represents AIHA Workplace Noise Increases Risk of Heart Disease, as D-liaison expert to the ISO Working Group on Social Re- Study Finds sponsibility (WG/SR) and on the U.S. Technical Advisory Group A new study conducted by the University of British Columbia’s (TAG) to ISO Technical Committee 26000 on Social Responsibil- School of Environmental Health in Vancouver suggests that a ity. “Best practices include making social responsibility integral noisy work environment can lead to heart disease. The study to an organization’s policies, culture, strategies and operations.” was published on the website of the journal Occupational and For more information, see Hogue’s article on page 27. Environmental Medicine. The standard can be purchased from the ISO website, EmpoweredNews.net reports that, according to www.iso.org. the study, workers exposed to a noisy environ- ment are two to three times more likely to de- NOISE velop heart disease than those who work in quieter environments. Authors of the study OSHA Proposes New Interpretation for Noise Standards classified persistent loud noise as unwanted, OSHA is proposing to issue a reinterpretation of the phrase intrusive sound resonating from manu- “feasible administrative or engineering facturing processes. controls” in occupational noise exposure Researchers analyzed data from 6,300 standards and to revise its current policy subjects who were at least 20 years old. to reflect this interpretation. In the The subjects were given physicals and blood OSHA proposal, “feasible” will retain its tests and answered questions regarding their health and common meaning of “capable of being lifestyle. Researchers found that loud noises elicit stress and the done” in order to enforce compliance release of chemicals that constrict coronary arteries and can with current noise standards. cause additional heart-related illnesses. The existing noise standards stipulate that feasible adminis- An abstract of the study is available at http://oem.bmj.com/ trative or engineering controls must be used to abate noise, and content/early/2010/09/06/oem.2010.055269. To read the Empow- PPE, such as earplugs or earmuffs, are to be worn when admin- eredNews.net article, visit http://empowerednews.net/?p=2530. istrative or engineering controls are insufficient. Currently, cita- tions for failure to use engineering and administrative controls 12 The Synergist I December 2010
  • 16. NEWSWATCH | DEPARTMENT MINING SAFETY investigation, according to a report in the Wall Street Journal. The 33 miners were trapped more than 2,000 feet under- Following Mine Rescue, Chilean Government Vows to ground for 69 days. Better Protect Workers To read the Wall Street Journal article “Chile, in Mine Res- The rescue of 33 miners from a collapsed mine in Copiapo, cue’s Glow, Vows Labor Reform,” visit http://bit.ly/ad6ARZ. The Chile, in mid-October has caused the Chilean government to CNN.com article “After a Final Day Together, Miners Begin to reevaluate its worker health and safety protections, according Disband” is available at http://bit.ly/dyIXWy. to an article posted Oct. 15 on CNN.com. After meeting with the miners, Chilean President Sebastian Pinera MINING SAFETY pledged to strengthen labor laws and improve work environments. He also Proposed Rule Would Reduce Exposure to Coal Dust vowed to see that Compania Minera In October, MSHA released a proposed rule that would lower San Esteban Primera, the company mine workers’ exposure to respirable coal dust in all under- that operated the mine, would cover a ground and surface coal mines. Part of MSHA’s “End Black portion of the millions spent on rescue Lung–Act Now” campaign, the pro- efforts. posed rule would blend previous reg- CNN.com quotes Pinera as saying, “Never again in our coun- ulatory actions and implement try are we going to permit work in such an unsafe and inhu- recommendations in the 1995 NIOSH mane environment as the San Jose mine. We are going to report “Criteria for a Recommended create a culture of respect for life, health and dignity of our Standard: Occupational Exposure to workers.” Respirable Coal Mine Dust” and the In addition to forcing Compania Minera San Esteban Primera 1996 “Report of the Secretary of to pay for part of the rescue expenses, the Chilean government Labor’s Advisory Committee on the Elimination of Pneumoco- intends to take administrative action and launch a congressional niosis Among Coal Mine Workers.” [Continued: 14] Circle Fax-back Card No. 6 November 2010 I The Synergist 13
  • 17. DEPARTMENT | NEWSWATCH [From: 13] The proposed rule would reduce the existing concentration TRAINING limits for respirable coal mine dust from 2 mg/m3 to 1 mg/m3 over a 24-month phase-in period, require the use of continuous OSHA Revises Policy on Training dust monitors, enforce the utilization of a single, full-shift sam- OSHA has modified the guidelines of its Outreach Training Pro- ple to verify compliance, and expand medical surveillance so grams to reduce the number of hours students spend each day miners could better manage their health. The proposed rule also in 10- and 30-hour training classes. The addresses extended work shifts and production shifts. new policy limits classes to a maximum of According to data from NIOSH, cases of black lung are on 7.5 hours per day; prior to this change, the rise. Young miners are even developing advanced and de- classes could last up to 13 hours a day. bilitating lung disease due to exposure to excessive amounts of OSHA instituted this policy change to pre- dust, and more than 10,000 miners have died from black lung vent students from being overloaded with within the past decade. information in a single day of training. To read the complete proposed rule as published in the Fed- In accordance with the new training eral Register, visit http://bit.ly/axmHr3. Comments are due Feb. policy, 10-hour courses must be conducted 28, 2011, and may be submitted via the federal e-rulemaking over a minimum two-day period and 30- portal at www.regulations.gov, via mail to MSHA, 1100 Wilson hour courses must be given over at least Blvd., Arlington, Va. 22209-3939, or by fax to (202) 693-9441. four days. OSHA will not accept classes To read the MSHA press release, visit that do not meet all program requirements or exceed 7.5 hours www.msha.gov/MEDIA/PRESS/2010/NR101014.pdf. Videos from per day. The agency has also set up an outreach fraud hotline at MSHA’s “End Black Lung–Act Now” Campaign are available at (847) 725-7810 where the public can report program fraud or www.dol.gov/dol/media/webcast/20101013-coal/. abuse. NIOSH data on black lung disease can be found at For more information, read the OSHA press release at www.cdc.gov/niosh/topics/pneumoconioses/. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table= NEWS_RELEASES&p_id=18606. Think all HSE Consultants & 1. Ye ars o Laboratories 2. U. S. lo f exp erien ce are the same? catio ns 3. # o f glo bal l ocati 4. Ac ons Put us to the test. credi ted l abs? 5. # o f cou ntrie s ser 6. # o ved f pro fessi onals 888.357.7020 www.us.bureauveritas.com 8. Ded icated client 9. Pr servic ofess e team ional ? Licen ses Circle Fax-back Card No. 7 14 The Synergist I December 2010
  • 18. NEWSWATCH | DEPARTMENT NACOSH chlorine, said Charles E. Adkins, OSHA ENFORCEMENT Regional Administrator, Kansas City, Mo., Labor Department Renews National in an agency press release. OSHA Launches Inspection Plan for Safety and Health Advisory Commit- OSHA claims the garrison willfully vio- High-Hazard Workplaces tee Charter lated procedures by supplying workers In August, OSHA began its annual in- In October, Secretary of Labor Hilda L. who were changing chlorine cylinders spection of high-hazard work sites under Solis renewed the with five-minute emergency escape the Site Specific Targeting 2010 (SST-10) charter of the OSHA breathing devices. OSHA procedures for program. The plan is intended to help National Advisory working with hazardous chemicals require OSHA channel its enforcement resources Committee on Occu- self-contained breathing apparatus or into workplaces with the highest rates of pational Safety and supplied-air respirators. injuries and illness. Health (NACOSH). The garrison can comply with the no- “Our goal is to prevent worker injuries NACOSH advises, tice, request an informal meeting with the and illnesses and save lives,” said Assis- consults with, and OSHA director in Wichita, Kan., or ask for tant Secretary of Labor David Michaels in makes recommenda- a hearing with the regional administrator an OSHA press release. “The Site Specific tions to secretaries of in Kansas City. Targeting program helps OSHA focus its labor and the Department of Health and The OSHA press release is available at enforcement resources to high-risk em- Human Services (HHS) on issues concern- http://bit.ly/cVut3W. ployers who are endangering their work- ing the OSH Act and improvements to ers’ health and safety.” workplace health and safety protections. The OSHA SST program inspects non- “Since OSHA’s inception, NACOSH has RECORD KEEPING construction workplaces with 40 or more played an important role in advising the employees. Based on work-related injury Nonfatal Workplace Injuries and secretaries of labor and HHS on worker and illness data compiled from a 2009 Illnesses in Private Sector Down in safety issues such as hazard communica- OSHA survey, SST-10 randomly selects 2009, BLS Reports tion, the whistleblower program and establishments from a list of 4,100 manu- According to the Bureau of Labor Statis- providing ideas and input on ways to re- facturing, nonmanufacturing, and nursing tics (BLS) 2009 Survey of Occupational duce worker deaths, injuries and ill- [Continued: 16] Injuries and Illnesses, nonfatal workplace nesses,” said Assistant Secretary of Labor injuries and illnesses among workers in David Michaels in an OSHA press re- private industry decreased to 3.6 cases per lease. “The members’ advice and recom- 100 equivalent full-time employees in mendations are extremely valuable 2009—a decline from 3.9 cases in 2008. because they have a wealth of knowl- Nonfatal occupational injuries and ill- edge and real-world experience on a nesses dropped from 3.7 million cases in wide range of worker health and safety 2008 to 3.3 million cases in 2009. In ad- matters.” dition, the number of private industry in- The NACOSH charter expires in 2012. jury and illness cases reported nationwide The OSHA press release is available at in 2009 that resulted in the need for time www.osha.gov/pls/oshaweb/owadisp.show off from work, job transfer, or restriction _document?p_table=NEWS_RELEASES fell from 2.0 cases per 100 workers in &p_id=18609. 2008 to 1.8 cases in 2009. The manufacturing industry reported a 23 percent drop in cases from 2008 to ENFORCEMENT 2009—the largest year-to-year decrease in OSHA Cites U.S. Army Garrison for injuries and illnesses since the North Potential Chlorine Exposure American Industry Classification System OSHA issued notices of unsafe and un- (NAICS) was first published in 2003. The healthy working conditions to the U.S. construction industry also saw a signifi- Army garrison at Fort cant decline in 2009 with its incidence Riley, Kan., on Oct. 15 rate dropping to 22 percent. The com- after an inspection bined decrease in cases reported in these found that workers at sectors make up 56 percent of the total the garrison’s water private industry decline in 2009 injury treatment plant were and illnesses. consistently exposed For more information, visit to hazards that in- www.bls.gov/news.release/archives/osh_1 volved a potentially 0212010.pdf. dangerous release of Circle Fax-back Card No. 8 December 2010 I The Synergist 15
  • 19. DEPARTMENT | NEWSWATCH [From: 15] and personal care facilities. The plan ex- data_General_Facts/Crowd_Control.html, standable, and more useful to our part- amines various factors such as the num- provides employers with recommended ners as a tool for protecting workers’ ber of injury and illness cases, the elements for crowd management plans. health,” said NIOSH Director John number of days a worker must stay away “Crowd-related injuries during special Howard. “Although the U.S. has made from work, and the number of employ- retail sales and promotional events have great progress in controlling work-related ees who received job transfers or work increased during recent years,” Michaels lead exposures since the enactment of restrictions because of injury or illness. told the CEOs. “Many of these incidents the Occupational Safety and Health Act, More information about SST-10 is can be prevented by adopting a crowd we must remain vigilant in recognizing available at www.osha.gov/OshDoc/ management plan, and this fact sheet and addressing this occupational hazard.” Directive_pdf/CPL_02_10-06.pdf. provides retail employers with guidelines Initiated in 1987, the ABLES program for avoiding injuries during the holiday is intended to build states’ capacity to ini- CROWD CONTROL shopping season.” tiate, expand, or improve adult blood lead In 2008, a worker was trampled to surveillance programs. More information OSHA Urges Major Retailers to Take death while a mob of shoppers rushed on ABLES is available at www.cdc. Worker Safety Precautions through the doors of a large store to take gov/niosh/topics/ABLES/ables.html. In early November, Assistant Secretary advantage of a Black Friday sales event. of Labor David Michaels sent a letter to For a copy of the letter sent to the CEOs EMERGENCY MANAGEMENT the CEOs of 14 major retail companies— and a list of the retailers they represent, including Kohl’s, Sears, Target and visit www.osha.gov/ooc/blackfriday FEMA Encourages Emergency Macy’s—urging them to take precautions letter.pdf. Managers to Plan for Entire to prevent worker injuries during Black Community Friday and other holiday sales events. LEAD In an address to emergency managers in Enclosed with the letter was the OSHA San Antonio, Texas, Federal Emergency fact sheet, “Crowd Management Safety NIOSH Releases Online Lead Management Agency (FEMA) Adminis- Tips for Retailers.” The fact sheet, avail- Database trator Craig Fugate encouraged attendees able at https://www.osha.gov/OshDoc/ A new online resource released by to consider the capabilities and needs of NIOSH in November will help users iden- the entire community, including people tify, monitor, and address harmful over- with disabilities and children, when exposures to lead, the agency stated in a planning for disasters. press release. The web page provides data on cases of elevated levels of lead in the blood of adults, and trends in www.RAECO.com those cases over time. Daily, weekly, and monthly rentals. Intended primarily for use by occupa- tional and environmental health profes- sionals and researchers, the web page allows users to customize reports by year, U.S. state, age group, type of expo- sure, industry sector, and gender. The “Considering the needs of all members data are drawn from the NIOSH-funded of our community and planning for Adult Blood Lead Epidemiology and Sur- worst case scenarios is exactly why we veillance (ABLES) program. Exposure in- need a strong emergency management formation from 2002 through 2008 is team—a team that FEMA is only one Your one-stop rental source for... available for 40 states. member of,” Fugate told his audience at Respirator t testing systems The new web page can be found at the 58th Annual International Associa- Air monitoring and sampling pumps Combustion e ciency analyzers tion of Emergency Managers Conference. Gas detection and monitoring “We know government can’t do it HVAC and ventilation test instruments alone—many of the most innovative Indoor air quality monitoring ideas for how we can protect all mem- Particulate monitoring bers of our community from the impacts Sound and noise level monitoring of disasters will come from you.” See our website for the full list Fugate then announced a FEMA- sponsored competition intended to gen- Save an automatic 5% when erate ideas for ways that communities you rent at www.RAECO.com! wwwn.cdc.gov/niosh-survapps/ables/ can become better prepared for disas- Need help with your rentals? default.aspx. ters. The winning idea will be featured Call 866-RENT-EHS (866-736-8347) “With this new web page, we are on the agency website. For more infor- pleased to make data from the ABLES mation about the competition, visit New instrumentation catalog! program more accessible, more under- http://challenge.gov/fema. Get yours at www.RAECO.com Circle Fax-back Card No. 9 16 The Synergist I December 2010
  • 20. NEWSWATCH | DEPARTMENT ENFORCEMENT IH Careers a Hot Topic in the News MSHA Asks Court to Temporarily Close From Yahoo! to the Wall Street Journal, media outlets have been giv- Kentucky Mine ing industrial hygiene and related professions a lot of attention lately: On Nov. 3, MSHA filed a motion with the U.S. District • For its video series “Career Paths,” the Wall Street Journal online Court for the Eastern District of Kentucky for a prelim- featured an interview with AIHA® member and EHS Director at inary injunction against Freedom Energy Mining Co.’s Emilcott, Paula Kaufmann, CIH. The video, available at Mine No. 1 in Pike County, Ky. This is the first time http://bit.ly/a5rNfW, shows Kaufmann performing a health and MSHA has used its authority to take legal action of safety audit and discussing what motivates her in her career. this nature. Freedom’s Mine No. 1 is owned by Massey Energy Co., which also owns the Upper Big Branch • CNNMoney.com, in collaboration with PayScale.com, ranked envi- mine in Montcoal, WVa., where 29 miners were killed ronmental health specialist as the 22nd best job in America with a in an April 5 explosion. 28 percent 10-year job growth and a median salary of $71,000. In its brief, MSHA claims Freedom Energy has con- Jobs on the list, which appeared in the November 2010 issue of sistently failed to investigate and manage crucial ele- Money magazine, are ranked by pay, job growth and quality of life. ments of its mining operations, and To view the list, go to http://bit.ly/9pjvhY. cites four specific safety areas • Investopedia, powered by Yahoo! Finance, listed IH as one of seven where the mine hasn’t properly jobs employers are desperate to fill. Investopedia reports that IH protected its workers. According to jobs are expected to increase by 14 percent within the next eight MSHA, Freedom Energy neglected years. Visit http://yhoo.it/b6FvDQ to read the article. to clear the mine of excessive accu- mulations of coal dust, failed to Have you seen industrial hygiene in the news? If so, let The maintain an adequate roof control Synergist know by e-mailing synergist@aiha.org. plan, failed to test and maintain the safety of electrical equipment to guard against [Continued: 18] Circle Fax-back Card No. 10 December 2010 I The Synergist 17
  • 21. DEPARTMENT | NEWSWATCH [From: 17] fires or explosions, and neglected to The guidance does not define or re- properly ventilate the mine of hazardous quire a specific control option for a par- and explosive gases. Freedom Energy ticular type of source because BACT is Mine No. 1 is located in a coal seam that determined on a case-by-case basis. In- emits excessive amounts of methane and stead, the guidance and resources pro- is prone to roof collapses—there have vide the basic information that permit been six major roof falls in the mine writers and applicants need to address since Aug. 11, 2010. GHGs. The guidance also provides exam- MSHA issued 1,952 citations and 81 local air permitting authorities identify ples of how permitting requirements orders during eight standard inspections cost-effective pollution reduction op- could apply. between July 2008 and July 2010. If the tions for greenhouse gases (GHGs) under In January 2011, industries that are court grants MSHA’s motion, Freedom the Clean Air Act, the agency stated in a large emitters of GHGs, and are planning Energy will be forced to temporarily close press release. to build new facilities or make major its mine until it fixes all dangerous condi- EPA recommends that permitting au- modifications to existing ones, will work tions and institutes an MSHA-approved thorities use the best available control with permitting authorities to identify health and safety management program. technology (BACT) process to look at all and implement BACT to minimize their To read the MSHA press release, visit available emission reduction options for GHGs. This includes the nation’s largest www.msha.gov/MEDIA/PRESS/2010/NR1 GHGs. After taking into account technical GHG emitters, such as power plants, re- 01103.pdf. feasibility, cost and other economic, envi- fineries and cement production facilities. ronmental and energy considerations, Emissions from small sources, such as GREENHOUSE GASES permitting authorities should narrow the farms and restaurants, are not covered options and select the best one. EPA an- by these GHG permitting requirements. EPA Issues Pollution Permitting ticipates that, in most cases, this process Information about EPA’s guidance is Guidance will show that the most cost effective way available from www.epa.gov/nsr/ghg New tools made available by EPA in for industry to reduce GHG emissions will permitting.html. November are intended to help state and be through energy efficiency. In Brief John Funk, a former Nevada Test Site worker who helped lead the fight for com- pensation for work-related illnesses, died Oct. 13 of complications from chronic obstructive pulmonary disease, the Las Vegas Review-Journal reported. (“Funk, ad- vocate for ex-test site workers, dies at 69,” Oct. 29.) Indiana OSHA was investigating the death of a 20-year-old student at the Univer- sity of Notre Dame who died while filming a practice of the Notre Dame football team when the scissor lift he was in tipped over from high winds. (“Declan Sullivan, Notre Dame videographer dies in accident, OSHA launches probe,” Washington Post.) The makers of Brazilian Blowout, a chemical hair-straightening treatment, stated in November that they would initiate legal action against Oregon OSHA following an agency alert that said the treatment contains dangerous amounts of formalde- hyde. (“Brazilian Blowout Formally Initiates Legal Proceedings Against Oregon OSHA,” www.sys-con.com.) Illinois Senator Dick Durbin called for an EPA probe of toxic diesel pollution in Chicago’s two major rail stations and inside the cars that carry commuters. In No- vember, the Chicago Tribune reported that riders on the city’s Metra transit system were exposed to levels of diesel soot up to 72 times higher than on the streets out- side the system. (“Metra riders subjected to high amounts of diesel soot,” www.chicagotribune.com.) Britain’s Health and Safety Executive (HSE) reports 152 worker deaths in 2009- 2010, a rate of 0.5 fatalities per 100,000 workers. (“The Health and Safety Executive Statistics 2009/10,” www.hse.gov.uk.) Employees of Ames Laboratory from 1955 through 1960 who developed cancer were granted compensation by the U.S. Advisory Board on Radiation and Worker Health. Ames Lab, a Department of Energy facility, was the site of secret research with radioactive materials, including uranium. (“Ames Lab uranium cause of cancer in workers; compensation claims approved,” Iowa State Daily.) Circle Fax-back Card No. 11 18 The Synergist I December 2010
  • 22. ® Go Green! Renew Your 2011 Membership Online! Continue to receive uninterrupted member benefits Connect with other professionals Receive current OEHS information Members who renew online prior to 12/31/2010 will be entered in a drawing for a $250 gift card!
  • 23. Insight EXPOSURE ASSESSMENT I RISK ASSESSMENT EXPOSURE ASSESSMENT Time for Modeling Toward a Culture Change for Industrial Hygienists BY STEVEN D. JAHN On a recent trip to my parent’s home in Connecticut, I received a “safe” exposures from our considered “professional judgment” book from my Dad to read on my way back to South Carolina. are grossly in error. The second is laziness. We should be chas- The book contained an appropriate reference for gauging our ing an effective occupational health program with our best ef- progress in the use of modeling tools in exposure assessment. fort, but we cannot muster the energy. The majority of modeling Many of us learned our craft from graduate schools and cor- is done by a handful of practitioners, and often for litigation or porate organizations that expected a professional technical de- regulatory reasons. fense of judgments made to protect worker health. We were expected to ferret out hazards that mattered and defend the ex- Attitude penditure of dollars toward controls (whether engineering or ad- So how can we spark a return to our foundation of decision ministrative). Demonstrating the “adequacy” of that posture was making, exposure assessment? By making a professional com- left to the ethics of the individual—and of the corporate auditors mitment to learning and using models. The second edition of who looked at the work (and possibly wrote the procedures and Mathematical Models for Estimating Occupational Exposure to trained us as well). Chemicals is ready to guide your schooling. Join us in moving If this description reflects your experience, then your attitude this critical tool to the forefront of exposure assessment. may have been as mine was: I declared myself to be a profes- And that book my Dad gave me? It was titled, Do the Right sional, short on time to document hazards that didn’t exist, and Thing. long on ethics. If you have read The Synergist or the Journal of Occupational Steven D. Jahn, CIH, is a senior IH technical advisor in Aiken, S.C. He can be and Environmental Health for any length of time, you recognize reached at steven.jahn@srs.gov or (803) 557-3828. that Tom Armstrong and Mike Jayjock have lobbied for years for a transparent defense of our professional judgments through modeling. Yet even today, exposure modeling is rarely used. This resistance to modeling is cultural; changing a culture is slow Resource work, and can be measured through what I call the three A’s: at- 1. Logan, P.W., G. Ramachandran, J.R. Mulhausen, and titude, atmosphere, and acceptance. P. Hewett: “Occupational exposure decisions: Can limited data interpretation training help improve accuracy?” Atmosphere Annals of Occupational Hygiene, 53(4):311–324 (2009). In 1980, OSHA was ten years in existence and I was an indus- trial hygienist in training. Our professional emphasis was on monitoring data, not models. (By the way, we still don’t have an exposure assessment standard to drive the right monitoring pri- Guidance for Exposure Modeling ority.) However, most of our judgments are rendered with no The second edition of AIHA’s Mathematical Models for Esti- sampling data.1 It is the rare occasion when statistically valid mating Occupational Exposure to Chemicals, edited by data populations drive exposure assessment decisions. Charles B. Keil, Catherine E. Simmons, and T. Renee Anthony, was released in 2009. Members can purchase this resource at Acceptance a discount of nearly 25 percent from the nonmember price. There are two reasons why our profession has not yet accepted Go to www.aiha.org/marketplace. exposure modeling. The first is fear of learning that supposedly 20 The Synergist I December 2010
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  • 25. DEPARTMENT | INSIGHT RISK ASSESSMENT Crossing a Threshold Do “Zero-Risk” Exposures Exist? BY FRANK MIRER Do observations of chemical hazards at high exposure levels predict risk at much lower levels? Or are there reliably “safe” (that is, zero-risk) doses or exposure levels for most chemicals other than carcinogens? To lay down the gauntlet, this column argues that the concept of a “threshold” in a population violates the principle of the exposure-response relationship. I agree there are population doses with minimal risk, perhaps practical thresholds for concern. But assuming a threshold assumes there is an exposure region where increasing exposure doesn’t increase risk. Our jobs as practitioners include communicating the risk of a chemical exposure at levels well below those where a hazard has been identified. Paracelsians fondly say that “everything” is a poison at some dose, as a way soft-soaping people exposed to a chemical already shown to a be a poison. (I think Paracelsus used that argument to defend using mercury as a medicine, based on an alchemical theory; probably he said or wrote it in Latin.) Opining about causation where one person among a larger group of similarly exposed individuals becomes ill is another side of that coin. In some situations, the illness is clearly associated with exposure to the chemical in some setting; in others, past evidence of association may be shaky. As practitioners, we rely mostly on authorities like govern- Defining “Zero-Risk” ment or scientific organizations to tell us the level of exposure We are taught that all chemicals exhibit an exposure-response where there’s a concern or probability of adverse effect. Since relationship: the lower the dose, the lower the risk. Is there a OSHA and NIOSH have done little in the past decade (or more) threshold—that is, the upper bound of zero-risk doses? A to bring exposure rules or recommendations in line with threshold dose implies a dose region in which there is no expo- emerging science, the main sources of such data are the EPA sure-response relationship—within this region, increasing the Integrated Risk Information System (IRIS) reference doses and dose carries no increased risk because the risk is zero. This re- concentrations (www.epa.gov/iris/) and the Agency for Toxic gion is a biological black hole: dose goes in, but no response Substances and Disease Registry (ATSDR) minimal risk levels comes out. (MRLs) for hazardous substances (www.atsdr.cdc.gov/mrls/ What evidence is there for a threshold? Proving the thresh- index.html). old (in a population exposure-response relationship) is as diffi- I tell my students to go to IRIS and ATSDR whenever they cult as proving any negative. I teach the concept of “Limit of have an identified chemical exposure level to evaluate. IRIS Direct Observation” (LODO)—the power of various methods to calculates a unit cancer risk for carcinogens, based on linear see the toxic potential of an exposure, if it were there. The low-dose extrapolation, and generates reference doses and con- LODO for laboratory studies is a risk of about 1 in 10 against a centrations for non-cancer endpoints by applying uncertainty zero background, the risk at the NOAEL or the benchmark dose. factors to a no-observed adverse effect level (NOAEL) as a point A background risk in control animals—for example, liver cancer of departure. Some of these values are aggressive (5 mg/m3 for in mice—moves the LODO upward. Some special designs (dis- toluene), and some are very aggressive (0.1 mg/m3 for xylenes). cussed below) might do a little better. (Remember that the This column provides arguments for applying these aggressive Supreme Court-derived border of “significant risk” is 1 in 1,000, limits in the occupational setting. or 0.1 percent.) 22 The Synergist I December 2010
  • 26. INSIGHT | DEPARTMENT For studies in people, the LODO is the population rate of the Important laboratory (and possibly human) carcinogens such as target condition. The population rate of lung cancer in Ameri- perchloroethylene (see “Percs at the National Academy” in the can men is about 5 percent, so the LODO is whatever excess is May 2010 Synergist) have not been shown to cause mutations convincingly exposure-related. Maybe a 6 percent risk would in short-term bioassays. be statistically significant, but it would be difficult to get this Maybe the most prominent and troubling “non-genotoxic” accepted for hazard determination in a single study. Epidemiol- carcinogen is dioxin. The consensus is that dioxin acts by binding ogy can be more sensitive to elevated risks than laboratory to the aryl hydrocarbon receptor (AhR). This interaction leads to studies, but has many other barriers and obstacles. effects on a host of organ systems—immune, reproductive—and at Plenty of known human carcinogens—like sulfuric acid mist— very low levels of exposure. AhR was not known when I was a are unregulated even after direct observation. But, at 10 percent real toxicologist back in the 1970s. EPA’s interminable update of excess, we are extending knowledge below the LODO—that is, the risk assessment for dioxin—the last draft went from EPA to the laboratory studies cannot confirm that a risk is less than 1 in 10. National Academy of Sciences in 2004—was sent back with com- It’s like the dark side of the moon before the Apollo missions— ments in 2006; EPA’s most recent response was released in May we knew it was there, but hadn’t seen it. 2010. EPA found low-dose risk for non-cancer endpoints as well Sometimes we get a window to test high-to-low-dose conti- as cancer (see http://cfpub.epa.gov/ncea/CFM/nceaQFind.cfm? nuity of risk. Environmental tobacco smoke is classified as keyword=Dioxin). Honestly, the hundreds of pages, dozens of “known to be carcinogenic to humans.” I voted for this classifi- calculations, and, I assume, hundreds of references were too cation in the National Toxicology Program (NTP) Report on Car- much for me to digest. cinogens sometime around the year 2000. This determination is Every two years the Institute of Medicine, by law, updates based on multiple epidemiologic studies in people, mostly com- the list of conditions suffered by veterans exposed to Agent Or- paring lung cancer rates among non-smoking spouses of smok- ange and presumably caused by dioxin. Vietnam veterans who ers with those of non-smoking spouses of non-smokers. The suffer these diseases get compensation. Many organ systems are lower rate of lung cancer among non-smokers extended the implicated beyond cancers, including diabetes and nervous sys- LODO downward. Cigarette smoke is a very low-potency car- tem disorders (see http://books.nap.edu/openbook.php?record cinogen (µg per µg), and the exposure gradient between direct _id=12662). The important point is that low-dose effects for and environmental exposures depends on which component of non-cancer endpoints are prominent in the risk assessment smoke is considered and which environmental exposure levels based heavily on laboratory results and are also found in the are assumed for the studies. But it could be 1,000-fold. assessment of people with dioxin exposure. The gradient between occupational and take-home asbestos levels also must be very large, so family mesotheliomas also Acceptable Risk provide evidence for high-to-low-dose continuity, and therefore There’s no doubt that a “significant” risk (in occupational lack of a threshold. The consensus is that the risk of cancer terms) persists at the NOAEL, whether cancer risk or other. The from ionizing radiation is also present at low doses, although risk assessment task includes extrapolating known effects into there are still deniers and advocates of the view that low doses the dose region where direct observation is not feasible. The are good for you (radiation hormesis). risk management tasks include deciding an acceptable risk. It might be useful to convert the extrapolation factors now used Mega-Mouse and Mega-Rat by EPA to calculate the reference concentrations in IRIS to risk In the mid-1970s, the “mega-mouse” study was planned to con- rates—I think the EPA benchmark dose software will actually do firm or deny a threshold. Part of the Pine Bluff Arsenal, a bio- this. The distance of extrapolation from the point of departure logical and chemical warfare facility in Arkansas, was dose to occupational levels is usually many factors of 10 less reconfigured as the National Center for Toxicological Research, than those in the general environment. The task is feasible, and which housed the study. The agent chosen was acetylaminoflu- it needs to be accomplished. Practitioners waiting for authorita- orene, an amine to which few humans might be exposed. Here tive results can look up the IRIS RfC, multiply by 3 to account is the abstract of an early mega-mouse report: for 24/7/365 exposures compared with occupational, and they Although bladder neoplasms exhibited a minimum effect level would be in the ballpark. (or a nonlinear response) for specific conditions, the total re- sults were consistent with a “no threshold concept.” The late- Franklin Mirer, PhD, CIH, is a professor in the Environmental and Occupational Health Sciences Urban Public Health Program at Hunter College School of Health appearing liver neoplasms displayed a nearly linear-type Sciences in New York. He can be reached at (212) 481-7651 or response that extrapolated directly to zero dose.1 fmirer@hunter.cuny.edu. A similar mega-rat study in England produced similar re- sults. Subsequent reinterpretations—by industry-associated sci- Resource entists—have claimed evidence for a threshold. Overall, the paradigm-testing experiment was like the tree that burned in 1. Farmer, J.H., D.W. Gaylor, and W.G. Sheldon: “Effects of Dose and Time in a Long-term, Low-dose Carcinogenic the forest with no one to smell it. Did it give off smoke? Study.” J Environ Pathol Toxicol 3(3 Spec No):17–34 (1980). The next stage of the debate was to concede the plausibility of linear low-dose extrapolation for “genotoxic” carcinogens but to argue a threshold for agents that did not cause mutations CONNECT for CREDIT in short-term bioassays but did cause cancer in whole animals. www.aiha.org/syntestseries December 2010 I The Synergist 23
  • 27. FEATURE | Extreme Makeovers EXTREME MAKEOVERS Tips for Improving EHS Graphics BY ED RUTKOWSKI B Bob Emery talks about data the way a novelist might discuss verbs. Currently vice president for Safety, Health, Environment and Risk Management at the University of Texas (UT) Health Science Center at Houston, Emery has worked in OEHS for 25 years, and he’s certain that the main reason why his OEHS colleagues struggle to win the ap- campus, one of the university’s major buildings flooded, rendering the bottom floor unusable. In the days following re- occupation of the upper floors, Emery’s team at the Health Science Center cre- ated graphs of indoor air quality data and posted them by the elevators, where University employees were sure to notice them. Instead of simply listing the data, the graphs clearly showed that air qual- ity measurements were within ASHRAE guidelines for IAQ. information. His lectures incorporate the ideas of American statisticians Edward Tufte and John Tukey, who have made important contributions to the field of in- formation design, and he often presents on the topic at conferences. Emery’s dual role allows him to chal- lenge his students with examples straight from his inbox. His assignments require students to create new presentations of existing data, and some of their makeovers are startlingly good. (A stu- proval of management is a seem- “When they were waiting to go to dent’s re-creation of BP exposure moni- their floor, they could actually see what toring data from the Gulf oil spill appears ingly innate difficulty making the relative humidity levels were, what in Figure 1.) data—the dry essence of exposure the temperature was—and they could see The Synergist recently spoke with monitoring—come alive. this within the context of these red lines Emery about data presentation. Excerpts “We function largely in the field of that showed the ASHRAE recommenda- from this discussion appear on the fol- prevention, so on a good day, nothing tions,” Emery recalls. “We had hardly any lowing pages. happens,” Emery says. “The problem is indoor air quality complaints, I believe that we’ve got to get better at explaining largely because people could see the data The Synergist: If you were to make a to various stakeholders all of the work within the context of the reference lines.” broad generalization, how would you that went on behind the scenes to make For Emery, data is more than raw characterize most OEHS professionals’ nothing happen. And part and parcel of numbers; it’s part of a narrative. When skills in data presentation? that is showing data.” his employees show him a problematic Bob Emery: I'm struggling to find a po- The event that crystallized the impor- graph, he’ll say, “You’ve got a good story lite term for “atrocious.” I don’t mean tance of data presentation for Emery was to tell, but this sure ain’t telling it.” He that in a bad way; it’s just sometimes Tropical Storm Allison, which dumped has ample opportunity to share this judg- we’re so focused on the trees that we 35 inches of rain on Houston in June ment with UT students, too: 20 percent of miss the forest. And that’s really what 2001 and caused $5 billion worth of his appointment is dedicated to teaching drove my interest in graphics, because in damage across Texas. On UT’s Houston a class on communicating public health my field, I see confusing graphics time 24 The Synergist I December 2010