Adam Finkel recently sent me a Commentary from an advanced
access publication (January 2016) of the Annals of Occupational Hygiene
entitled “Hygiene Without Numbers” by Hans Kromhout. Adam knows me and knows that I could not read such a piece an NOT comment.
I have never met and do not know Dr. Hans Kromhout, except by reputation, but I
found his words to be right to the mark in his two pages of comments which I
would be happy to forward to anyone requesting it of me at mjayjock@gmail.com.
Hans Kromhout described control banding as a "numberless intervention" and generally criticized its adequacy. Indeed, I have always been frankly wary of control banding, which in
my opinion, uses available and typically quite limited data to takes educated
guesses at the ranges of toxicity to provide the level of needed control at
various bands of exposure. When combined
with “exposure banding” one takes a similar banding estimate approach to the
level of exposure that might be extant to get some notion of risk. I CAN see this as the FIRST steps in a
process aimed at understanding and controlling risk for a large number of
chemicals but, like Dr. Kromhout, I do not see it as the end game. There is simply too much uncertainty related
to underestimation or, on the other side, overestimation of risk and both conditions
are unacceptable for obvious reasons.
Everyone wants to “add value” to their organization and be “cost-effective”. These are well-worn and, on their face, not
unreasonable precepts enshrined in our psyche over at least the past 20-30
years especially in Corporate America.
Indeed, I believe that these personal/professional drivers have fed the
rush to banding. The bottom-line for me
is that, according to my mother, there is no free lunch. When one is committed to trying to understand
the risk to human health from exposure to the vast majority of chemicals in
commerce, we face an enormous short-fall in basic information related to both
the toxicity and exposure associated with our interactions with these chemicals
in a modern society. I see banding as a
response to the pressures that result from this uncomfortable situation. As indicated above, I see it is a positive
initial move but, I believe, in the majority of cases it does not reasonably or
adequately assess the risk.
Risk assessment desperately needs data and the subsequent
modeling of that data as the application of the scientific method to interpret
that data and adequately estimate the level of risk. That is, we need data on both the toxicity
and exposure which should be accompanied by modeling these data to inform our
confident knowledge of and decisions concerning the risk posed.
Like food and water, I believe that, freedom from unacceptable risk to
chemicals should be considered to be a human need and its importance and
provision should be recognized and addressed as such.
Spending the money to get the “numbers” will be much more
expensive than proceeding with banding as the end game; however, it will be “cost-effective”
relative to preventing unacceptable exposures and risk (or over-regulation). This should be an important precept for any general society that truly values both its general economic health
and the physical health of its citizens.
