Monday, December 2, 2013

Balancing the Risk Assessment Client’s Needs with Yours

I used to work at the now defunct Rohm and Haas Company.  For many years I did risk assessment for the businesses.  I mentioned to a colleague once that I was having trouble figuring out who the client was on a particular project I was working on.   He seemed perplexed and ask me what I meant by the term “client”.    I told him that clients are the folks that get and use our analyses.  Doing risk assessment in a corporate setting they may not be (and often are not) the ones who we report to or those who determine our rank and salary but they are critical nonetheless.   To the extent that we do a good job for them is the extent that we remain gainfully employed.

It should be noted that in our business we have both clients and charges.   Clients are roughly defined above but our charges are the folks on the receiving end of the exposures that we estimate.   We have a professional and moral responsibility to all these folks to get it right.

Clients, because of their position, can be typically demanding.   Clearly and appropriately, they want to get an answer that satisfies their needs using the least possible expense in the process.  For your part, you essentially want to do the same; however, it is our responsibility to render these answers in a realistic manner.   We need to admit to and deal with the inevitable uncertainty borne of any analysis and put that uncertainty into context for the client.

A prime example of this balancing act for me comes to mind involving an additive that was used in motor oil.   The additive existed in new motor oil but not in oil that was used.   I was asked to do a risk assessment on the additive in this application.  Data and modeling indicated that inhalation exposure was not a factor; however, dermal exposure to fresh oil during the oil changing process could be.    I assumed the following scenario.  
  •  Commercial oil changing (e.g., Jiffy Lube)
  • 10 oil changes per day
  •  Fingers of both hands covered with new oil during change
  •  Instantaneous and complete absorption of the additive by this dermal exposure

Let me know if you are interested in some of the details of the subsequent assessment and I will let you know by email or cover it in a future blog if enough folks are interested.

Because of my own experience at changing oil (I am very sloppy) and my lack of data otherwise, I felt comfortable that this scenario would definitely and appropriately OVERESTIMATE the exposure potential of this material.  More important, given a classical precautionary approach, I did not feel personally comfortable changing any of these assumptions on my own.

The client argued that it was indeed a worst case and told me that the above assumptions should be less stringent.   At that point, I told him/her that it was in fact their business and that they definitely should have more information/insight than I relative to these assumptions and that they were free to change any of them. However, I would need them to write down their assumptions and the bases for them which would be incorporated into the risk assessment as a reference.   Faced with this possibility, they declined to take this approach and agreed with the above assumptions as a working worst case.

An alternative approach would be to commission studies of commercial oil changing facilities to determine a distribution of number of changes per day and a dosimeter (e.g., washed cotton gloves that would be extracted and analyzed afterwards) study of amount of new oil that gets on the hands of these workers per oil change.   Another approach would be to do a dermal absorption study using human or animal skin.  (Note: I will get into dermal absorption testing and modeling in a future blog)

Both of the above approaches could be quite expensive but would almost certainly significantly lower the estimated level of exposure to workers.

The bottom line here is that I had to draw line relative to where my comfort level was regarding these assumptions.   I had to use my best judgment as to my skill level to ultimately trade conservatism for data and vice versa.    The client needed me to tell him/her (i.e., to professionally certify) that their product was “safe” in its intended use.  Indeed, I needed to provide an analysis that accomplished this same end for me as well.

Ultimately, the assessment using the above assumptions did not serve the client’s needs.   Indeed, it turned out that more data was needed and obtained to make the case for safety in which both the client and I were comfortable with the results.   The client, of course, became temporarily poorer having paid for the study and data but ultimately richer in the confident knowledge of that their product was safe.   Arguably the “charges” or folks receiving the exposure in this assessment were also reasonable well-served.

This brings me to the topic of the next blog:  Risk Assessment Uncertainty or How Safe is Safe?


  1. i quite reason and agree with you. Client at times wants to play 'he-who-pays-the -piper......' but that cant be possible. As OH professionals our works will bounce back on us. If we do the right thing we get appreciated for it but if do the wrong thing it may backfire on us, especially if it impacts negatively on the clients.

    Please i will like to have a copy of the risk assessment at

  2. Asking the client to document their assumptions and being part of the assessment is vital. We see this on a regular basis when doing priority assessment for asbestos. Clients do not want to see anything with high risk and try to dumb down everything to low. When asked to provide their assumptions in writing they are less willing to put their 'ass' on the line. I have had clients ask to have their names removed from the assessment when in fact they have provided the critical data.

    1. Hi Paul,

      I understand completely. It is just part of the process that we need to be continually aware of. Clearly, if a client backs away from their assumptions, then you are free to put in other assumptions for their review.

      Best Regards,

  3. Mike,
    Your assumptions are as good as the clients'. Were your assumptions based only on your limited experience in oil changing? Or did you use exposure factor from models like Consexpo or US-EPA Exposure Factors Handbook?

  4. Hi Wouter,

    The assumptions of how much oil would stay on the hand per cm2 was from the EPA data. The assumption of how many cm2 of skin were covered was based on my own very limited experience. The assumption of everyday exposure and complete and instantaneous absorption were designed to be worst case based on a lack of information.