MANAGING BEST PRACTICES: The Faroes Statement:
October 1, 2007
A group of some 200 international scientists in environmental health, chemistry, biology, epidemiology, and pediatrics came together in May 2007 to issue the “Faroes Statement,” (http://www.pptox.dk/Consensus/tabid/72/Default.aspx) a warning that human health effects of developmental exposure to chemicals in the environment are real, serious and require prompt attention.
According to the Faroes Statement, “Prevention should not await definitive evidence of causality when delays in decision-making would lead to the propagation of toxic exposures and their long-term, harmful consequences.”
New risk assessment frameworks
The Faroes Statement (issued at the International Conference on Fetal Programming and Developmental Toxicity held at Torshavn, Faroe Islands) is sandwiched between two new risk assessment guidance reports that describe the scientific principles to be considered in assessing health risks to children.
These reports are available on the Web sites of the U.S. Environmental Protection Agency and the World Health Organization.
Both the EPA and WHO reports define “child” and “children” as life-stages that begin at conception. This is the concept behind the Faroes Statement that encourages public health interventions at the earliest stages of life â€” where timing of chemical exposure is just as important as the magnitude of exposure.
EHS pros should be aware that about 55 percent of all children in the U.S. are born to a mom who works. This underscores the importance of occupational settings as potential sources of exposure when assessing risk to “children.”
Prevention – workplace legislation
Several new laws should encourage prevention efforts called for in the Faroes Statement:
• OSHA’s Advanced Notice of Proposed Rulemaking to amend the hazcom standard includes provisions to reduce the reporting requirement for reproductive toxicants on MSDSs from 1.0 percent to 0.1 percent to conform to global harmonization of chemical hazards.
• The European Union’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) law, which came into force June 2007, classifies reproductive toxicants as chemicals of “very high concern.”
• Assembly Bill 515, which (as of September 1, 2007) is pending approval before the California legislature, would require the state Standards Board to set the “highest priority protections” for workers against substances that may cause cancer or reproductive or developmental toxicity within the scope of the state’s Proposition 65. Health-based occupational exposure limits would be derived from existing and newly developed risk assessments (http://www.oehha.ca.gov/air/acute_rels/allAcRELs.html) by the California Office of Environmental Health Hazard Assessment (OEHHA).
Prevention – voluntary actions
Actions that support the Faroes Statement are expected to lower causation defense hurdles and open up more employers to tort lawsuits that claim a prenatal injury. Concern over possible lawsuits and the potential to better control health care costs are expected to help drive voluntary actions by employers to further address developmental toxicant exposures.
If you haven’t focused before on controlling developmental toxicants, now is the time. First, discuss this topic with your company’s management. Explain what’s going on and tell them you would like to create an inventory of developmental toxicant chemicals in the workplace.
An inventory may be created by comparing chemicals at your worksite maintained in your hazcom program, or elsewhere against the more than 200 developmental toxicants found at the California Prop 65 list (http://www.oehha.ca.gov/prop65/prop65_list/files/060107LST.pdf). This is not the only list available for developmental toxicants, but it’s a good start. If developmental toxicants are found, conduct a qualitative exposure assessment. Use a risk matrix if necessary to rank exposures. Do not collect air samples at this stage.
Your objective is to gather enough information to develop a risk report for management. Give management some idea of the scope of the problem. Any uncontrolled exposure of a developmental toxicant to an employee should warrant more follow-up.
Next, either plan to substitute the developmental toxicant with a less hazardous chemical, and/or develop an exposure-monitoring plan. Decisions should be made as to which limit will be used to determine if exposures are acceptable. Here’s a hint: OSHA’s permissible exposure limits won’t work. Determining the exposure limits to use is complex and might require the services of a Certified Industrial Hygienist, attorney or other professionals. Determine the time and expense for these activities and report back to management.
If management gives you the green light, then develop the elements of a reproductive and developmental health program and be ready to implement. Assure that no actions discriminate against someone who may be pregnant. Consider medical monitoring, risk communication, etc. Exposure results will direct subsequent actions. At this point, your workplace is supporting the intent of the Faroes Statement.