Archive for the ‘Industrial Hygiene’ Category
With all of the handwringing, I mean debate, about health care reform these, I wonder if anyone is going to get around to talking about and dealing with some of the underlying factors that would actually keep us from getting sick. Or, are the conversations going to continue to be about money and political power? Trying to do things to reduce the disease burden, which might correspondingly promote reform, doesn’t seem to be a prominent part of the discussion yet.
What prompted this line of thought was the announcement that David Michaels was being nominated as administrator of the Occupational Safety and Health Administration (OSHA). Dr. Michaels is an epidemiologist, and has prior experience with issues of protecting worker health. He will have a role in reducing the occupational disease burden, which indirectly may support health care reform.
How important is occupational disease? The annual burden of occupational disease mortality was estimated in 2003 by NIOSH researchers to be 49,000, with a range from 26,000 to 72,000. When added to the approximate 6,000 deaths from occupational accidents, work becomes the 8th leading cause of death in the U.S., after diabetes and ahead of motor vehicle accidents. The causes of deaths from occupational diseases were selected respiratory diseases, cancers, cardiovascular disease, chronic renal failure, and hepatitis. The annual cost of occupational illnesses and injuries has been estimated to be between $128 and $155 billion per year.
Something that might help reduce the occupational disease burden is to bring occupational exposure standards up to date, and make them relevant in light of today’s toxicological and epidemiological research.
The Occupational Safety and Health Administration (OSHA) is responsible for developing standards that will assure, “. . . that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure to the hazard. . . for the period of his working life.” In other words, achieving a safe and healthful workplace occurs through setting enforceable workplace standards that are based on allowable limits for worker exposure. OSHA hasn’t done a lot of exposure standards development in recent years. The easy answer would be to blame the G.W. Bush Administration business-friendly policies as the reason for this inaction. But exposure standards had been a problem long before the Bushies seized power.
OSHA sets enforceable Permissible Exposure Limits (PELs) which are regulatory limits on the amount or concentration of a hazardous substance that can be in the air in a workplace. When the OSH Act was enacted in 1970, OSHA needed PELs for lots of hazardous substances, right away. For this purpose OSHA reached out to use Threshold Limit Values (TLVs). TLVs are non-enforceable guidelines developed by the American Conference of Governmental Industrial Hygienists (ACGIH). TLVs “refer to airborne concentrations of substances, and it is believed represent conditions under which nearly all workers may be repeatedly exposed, day after day, without adverse effect”.
Years passed. TLVs were updated from time to time. The National Institute for Occupational Safety and Health began developing Recommended Exposure Limits (RELs), non-enforceable exposure limits similar in concept to TLVs. In 1989, OSHA tried to update its PELs, by adopting TLVs and RELs which presumably were based on more recent and better scientific data. That rule was thrown out of court in 1992 ironically in a suit brought by the AFL-CIO. The court directed OSHA to do risk assessments. . . on nearly 400 chemicals. So, the PELs returned to their obsolete, 1970 values (when OSHA was first enacted) which in many cases are based on even older science. With few exceptions, OSHA hasn’t attempted to promulgate new exposure standards, and Congress apparently hasn’t seen fit to push matters along, either.
The situation isn’t all bleak. TLVs have been updated, and while they are non-enforceable, the employers who are concerned about protecting the health of their workers have some better benchmarks than PELs. While NIOSH hasn’t been involved with standards development in awhile, EPA continues, slowly, to evaluate the dose-response of chemical substances through IRIS, the Integrated Risk Information System. Someday though, the EPA toxicologists and the industrial hygiene community will need to get on the same page regarding how to set thresholds of protectiveness – there are distinctly different philosophies used for the general public versus workers. That’s a topic for another day.
Looking at Dr. Michael’s biosketch, it’s apparent that the man knows something about exposure limits. Should his appointment be confirmed by the Senate, it will be interesting to see how he responds to the challenge of reforming PELs.
I’ll update this with links later. I’m tired, and there’s too much to do right now.