This blog is being published during the week of the AIHA
Annual Conference in San Antonio, TX. I
do not know if that will be a good week for readers of this blog because of their
potentially heightened professional involvement or a bad week because they will
be tied up at the conference. In any
event I have chosen this topic for this week because of the importance of this
subject matter.
This week’s blog is really the work of my friend and
colleague Adam Finkel. Adam worked at
OSHA in the 1990s and was perhaps the earliest advocate for what has come to be
known as Risk Based Occupational Exposure Limits (RBOELs). I have discussed RBOELs in this blog before,
to recap they are OELs that are set at some quantitative level of putative risk
(1 in 1000 has been suggested) determined by the modeling analysis of toxicological
data. RBOELs have been used for
carcinogens by the EPA and others for some time but Adam (and I and others) are
proposing that it be used more broadly for all OELs with enough documentation
to set an OEL.
Dr. Jimmy Perkins and I have been conducting a series of
teleconferences with members of the professional community with a stake and
standing in this process. A few weeks
ago Adam presented to this group. I
would be happy to send his full presentation (PowerPoint slide deck) to anyone who requests it at mjayjock@gmail.com. In the meantime I am going to present some
bullet points from his talk that I found particularly frank, to-the-point and
compelling. No one could ever accuse
Adam of beating around the bush!
What do the various kinds of limits ACTUALLY tell the worker who knows
(roughly) what concentration s/he is being exposed to, but wants to know how
dangerous it is?
• The OSHA PELs actually indicate levels that
lawyers and economists decided were economically feasible for most or all
employers to meet! There is lots of
cutting-edge risk science in the Preambles to the PELs, but the
numerical limits themselves reflect (anemic) determinations about feasibility. (the
word “anemic” in this paragraph is a personal judgment based on my (Adam’s) 12
years at OSHA– every other word is, I assert, unimpeachable)
• The ACGIH
TLVs indicate levels that very smart, energetic, and creative volunteers
together decided met some unknown balance of “reasonable assurance of safety”
and reasonable achievability in the workplace.
Every such judgment is chemical-specific, not generic.
• At
concentrations above or below the PEL or TLV, no knowledge about how
safe or how dangerous is or can be transmitted.
The leaders and rank-and-file of the occupational health world are
estranged from risk assessment, and the rift is widening
- long-standing moral distaste for risk assessment among labor unions, OSHA, NIOSH, etc.;
- tendency to blame risk assessment for delays and failures in the regulatory process;
- belief among many in corporate OHS that risk assessment is “voodoo” (see next slide –presented in the full slide deck but not herein)
- (mistaken) belief that risk assessment is overly “conservative” (see any of 8-10 articles by Adam Finkel on this issue);
- unflatteringly defensive posture (“with us or against us”) from the TLV Committee and AIHA;
- rise (esp. internationally) of “control banding” and other qualitative “alternatives” to risk assessment
An Action Plan and Cost Estimate for Developing 200 RB-OELs:
Adam envisions a two-step process:
• which study(ies) to select;
• how to convert exposures across species;
• “reference person” parameters;
• dose-response defaults and process for supplanting them
2. “Turn the crank” for @ 200 common substances with serious and irreversible health endpoints.
Adam thinks this could be done with 10 people, one year, and $750,000.
Of course, there is considerably more technical detail available in
the slides which, again, I will be happy to send to anyone who asks for them.
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