Blogging is a
remarkable media; indeed, this blog has opened communication among colleagues
in a manner that I did not anticipate.
This week’s blog represents a prime example.
You may remember that two of the last three
blogs deal with the subject of sampling statistics in which I tried to make the
point that exposure is naturally quite variable and that by just taking one or
a few samples, we can be tricked as to whether a workplace is really in
compliance relative to an OEL. The blogs
advocated using good statistical software such as IH STAT to help interpret the
data.
In response to these blogs I heard from a
respected colleague who has a lot more field experience as an IH than I
do. Indeed, I would describe him as a seasoned
and very thoughtful exposure assessor. Because he does not want to jeopardize his
future employment opportunities he has asked that I keep his comments anonymous
which I am pasting below:
“I think that the AIHA as an association has
failed to a great degree to educate industry about this particular failing of
our profession [the severe limitations of small sample size]. I'm not
aware of a single piece that has ever been produced that attempts to educate
the layperson (most business owners are) about the limitations of small sample
sets.
I also think that a pertinent question has
been missed by the IH community. That is - a reality-based question:
would a chemical-handling business be better off by having a professional
IH visit and observe their processes, and conduct a single sample vs. no visit
at all? I have lost sleep over this. Having worked with hundreds of
small (and medium, large) businesses over the years, I recognized this issue
soon after attending my first continuing education course on statistics back in
the early '90s.
The reality is that a sizable proportion of
chemical handling businesses will NEVER find their way to taking ANY samples.
Of the ones that do, VERY FEW would ever entertain the idea of repeat
sampling. This bothered me so much, that for a while I started giving
proposals to clients with an explanation of my own regarding statistical
limitations, and providing them two options in proposals - one with a single
visit/sampling event, a second (obviously more expensive) option that would
provide more confidence in conclusions reached - and leave the decision with
them. Maybe I'm not a very concise scientific communicator, or just not a good
salesman, but NONE of them ever opted for the multiple sampling option.
Another issue addresses a level playing field
for consultants. This is really important because if you look at the
demographics of the AIHA, consultants are the single largest group, and likely
perform more than half of all exposure assessments. If I were to
immediately insist that my new customers only go the repetitive sampling route,
I would be out of business as a consultant tomorrow. There will always be
someone else to step in that gives the customer what they want. Luckily, my
larger, more sophisticated clients will opt for building data validation over
time through repeated sampling events, but they are still few and far between.
Lastly, and sadly – OSHA regulations simply
don’t address the issue adequately.
Other than a few of the substance specific regulations for repeat
sampling, there is no legal impetus for employers to provide a statistically
sound approach to exposure assessment.
Hey - thanks for letting me spout off! This
is truly the 'dirty little secret' of the IH field, and in my opinion - no
amount of shaming is going to solve this.”
I
appreciate this expression of opinion and truth and I know this person enough
to believe he is correct.
From my perspective, I believe
that taking one sample is MUCH better than taking none as long as you attempt
to factor in the very large uncertainty associated with such action.
Assuming that a geometric standard deviation of about 2 is typical for
workplace exposures, then, in my opinion, a single sample value that comes out
to be less than 10% of an OEL is a pretty good indication that the average
exposure will be below the OEL at least 90-95% of the time. If true, OEL/10 could become the new action
level for single samples. Indeed, I
would love to have some sharp statistical minds to look over this suggested
approach and comment.
Another way of appropriately using but a single sample is to be sure you monitor reasonable worst case. That is, if possible, be sure that your single sample is capturing reasonably foreseeable worst case. Such factors as maximum product rate and/or minimum ventilation rate would be examples of this approach.
Another way of appropriately using but a single sample is to be sure you monitor reasonable worst case. That is, if possible, be sure that your single sample is capturing reasonably foreseeable worst case. Such factors as maximum product rate and/or minimum ventilation rate would be examples of this approach.
My sense of all of this is that it seems to point directly to the value of modeling in determining actually what scenarios and conditions should be monitored using our precious resources.