by Eileen Senn, MS

OSHA’s intention to finalize a list of chemicals on which to focus the agency’s efforts to address outdated rules on workplace chemical exposures was officially announced in the December 1 issue of OSHA Quick Takes and described in my November 17 post, “OSHA Poised to Action on Chemical Hazards.” No matter what approach or combination of approaches OSHA ultimately takes on chemical exposures, employer education and training must lay the foundation for voluntary compliance and enforcement. OSHA will need to undertake a campaign to teach employers, employees, and union leaders how to find and fix chemical exposures. I believe that the lack of such efforts has been a glaring omission standing in the way of OSHA achieving its mandate of having each employer furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.


What’s on the Web is Inadequate

Neither OSHA nor NIOSH has a publication or webpage to clearly and completely explain how to find and fix chemical exposures in a way that is comprehensible to laypeople and applicable to all chemicals. Much of what is currently on the OSHA and NIOSH websites is either focused on basic Hazard Communication on chemical hazards or toxicity information for specific chemicals. This reflects one of the problems with OSHA’s current regulatory approach to chemicals—one based on extensive, complex, independent standards on just a few specific chemicals.

Most OSHA website information on finding and fixing chemical exposures is too technical or not integrated into an understandable whole. If employers, workers, and union leaders go looking on the website, they will not find much that is useful to them. If they dig deep enough, they may manage to find scattered pages on:
*chemical sampling
*dermal exposure
*direct reading instruments
*hazardous and toxic substances
*medical screening and surveillance
*permissible exposure limits
*personal protective equipment
*respiratory protection
*sampling and analysis
*sampling and analytical methods
*surface contamination
*ventilation

I believe most employers, workers, and union leaders without specific safety and health expertise would only be confused by these pages. This sad state of affairs is most likely due to the unfortunate fact that finding and fixing workplace chemical exposures in the U.S. has been historically treated as the exclusive province of industrial hygienists and inextricably tied to air sampling and exposure limits.

Better Chemical Training Needed

In another example of what needs to change, OSHA will need to create a course or two on finding and fixing chemical exposures. At the OSHA Training Institute in Arlington Heights, Illinois and the forty plus OSHA Training Centers around the country there are only two classes that address something more than basic Hazard Communication. There is a a 1-day Health Hazard Awareness course for employers and employees costing $225, and a 4-day OSHA Guide to Industrial Hygiene course costing $750 with a prerequisite 4-day course also costing $750. The latter course is primarily for OSHA personnel and available to employers only on a space available basis. It is clearly too expensive and too technical for the needs of employers, workers, and union leaders.

The outline of what OSHA needs to teach employers, employees, and unions is contained in a New Jersey Work Environment Council checklist called “Finding Chemical Exposures and Negotiating Fixes.” The checklist lays out seven steps:

Step One: Obtain names of workplace chemicals

Step Two: Identify health and safety hazards of chemicals

Step Three: Ask workers if they are experiencing symptoms or illness

Step Four: Determine exposure potential to chemicals

Step Five: Implement general good practice control measures

Step Six: Identify and implement specific good practice control measures

Step Seven: Implement periodic maintenance and evaluation of control measures

These steps are similar to the steps laid out in ANSI/AIHA Z10–2005 Occupational Safety and Health Management Systems, based on the “Plan-Do-Check-Act” cycle.

OSHA needs to go beyond telling employers what to do technically to teaching them how to approach finding and fixing chemical exposures organizationally. Previous OSHA standards that have done this include Hazard Communication and Process Safety Management.

I can recommend several other publications OSHA can borrow and build on. One of my favorites is the United Kingdom’s COSHH Essentials publication “Working with Substances Hazardous to Health”. In ten pages, the reader is efficiently led through the steps of looking at each workplace chemical, thinking about the work tasks involving the chemical, assessing exposure risk, learning about and choosing control measures, and checking and maintaining control measures. Another excellent COSHH Essentials resource is “Easy Steps to Control Chemicals”, which has over 250 control guidance fact sheets, including 60 generic factsheets on ventilation, engineering control, and containment.

OSHA is welcome to borrow and build on Controlling Chemical Exposures: Industrial Hygiene Fact Sheets, written ten years ago for the New Jersey Department of Health and Senior Services. This publication has an overview of methods for controlling workplace chemical exposure followed by concise guidance on 16 components of industrial hygiene controls.

Technical Tools OSHA Can Build On

To support employers’ chemical assessment and control efforts, OSHA should create databases of assessment tools, best practice controls, and substitutes. For example, the European Agency for Safety and Health at Work has created a Risk Assessment Tools Database, with guides, guidance documents, handbooks, brochures, questionnaires, and ‘interactive tools.’ This includes free software with downloadable applications which are usually sector-specific. OSHA should produce narratives descriptions and checklists of best practice controls for industrial unit operations such as degreasing, production facilities such as cement plants, and construction work such as cutting wood products.

There are many sources of information on engineering controls for chemical contaminants but they are hard to find. NIOSH has issued many control technology publications but they are buried on their publication pages. Particularly useful are the 31 Hazard Control documents issued from 1996 to 2001.

OSHA should also collaborate with specific industry sectors to develop eTools like the one on engineering controls for Secondary Lead Smelting. Also very useful model are the OSHA Small Entity Compliance Guide Fact Sheets produced when the Methylene Chloride Standard was promulgated. For chemical exposures, there are OSHA eTools on respirators, silica, and battery manufacture and Expert Advisors on asbestos and lead. More of all these types of materials and tools are needed.

What a Robust Educational Campaign Looks Like

A modern educational campaign should include print, audio, audio-visual, electronic, web-based and other components – factsheets, booklets, checklists, podcasts, videos, online tutorials, webinars, technical aids, tool kits, training curriculum and sessions, conferences, symposiums, awards, and opportunities for partnerships. Examples of excellent campaigns are the EPA Indoor Air Quality Tools for Schools, and Indoor Air Quality Design Tools for Schools programs, designed to give school districts, parents, and school staff many tools to improve school environments for both staff and students. Whoever becomes the new Director of the OSHA Office of Communications should look at what EPA has done for ideas and inspiration.

Eileen Senn is an industrial hygienist who has performed occupational health work for government and unions for 40 years. She was an OSHA industrial hygiene inspector in Philadelphia for eight years in the 70s and 80s. She directed an OSHA New Directions training grant from 1979 to 1981. She worked in occupational health surveillance for the state of New Jersey from 1986 to 2002. She has been an Independent consultant for the past eight years. She is perhaps best known for her seminal article, Playing Industrial Hygiene to Win.