MANAGING BEST PRACTICES: Who sets the limits?

February 1, 2005
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To recognize the value that student research can bring to EHS, this month’s column is written by Gregory S. Mason, a doctoral student at the University of Toledo. Greg summarizes his timely research topic: Who should establish workplace exposure limits to reproductive toxins?

By 2010, 70 percent of women worldwide will be employed during their childbearing years. The International Labor Organization’s Maternity Protection Convention of 2000 calls for all employers to conduct risk assessments for workers who are pregnant to ensure the health and safety of her or that of her unborn child. Employers in the European Union are now bound by regulations to conduct these risk assessments.

With few exceptions (such as ionizing radiation) there are no similar regulations in the U.S. Still, a growing number of U.S. employers are conducting risk assessments for pregnant workers for various reasons.

But assessments for pregnant workers are handicapped because nearly all workplace chemical exposure limits (REL, PEL, TLV, etc.) are established for healthy working adults — not an embryo/fetus of a working mother.

Published methodologies do exist, though, to calculate an exposure limit for an embryo/ fetus from workplace chemicals. One source: “Evaluating Chemical and Other Agent Exposures for Reproductive and Develop-mental Toxicity” (National Research Council 2001). Using these methodologies a chemical such as toluene, with a current threshold limit value of 50 parts per million, would be reduced to about 10 ppm.

Who protects the embryo/fetus?

Several public and private organizations establish worker exposure limits to chemicals. But which should establish exposure limits to protect an embryo/fetus of a working mother? My research asked employers this question.

I developed a confidential survey questionnaire and cover letter which were mailed, along with a self-addressed stamped envelope, to a sample of employers that developed Toxic Release Inventory (TRI) reports required by EPA.

My sample was composed of 100 employer TRI “public contacts” in Ohio and Michigan (200 total), ranked by pounds of chemicals known to be reproductive toxins released into the air.

Selections of organizations were arranged in alphabetical order to minimize bias. The selections (with acronyms spelled out) were: ACGIH; AIHA; Chemical Manufacturer; Employer; Employee Representative (e.g., union); EPA; Insurance Company; Local, State or Federal Health Departments; NIOSH; OSHA; World Health Organization; and Trade Group (e.g., American Chemistry Council).

I also asked if exposure limits for reproductive toxins were necessary. And finally, an area was provided for comments. To maintain confidentially, the questionnaire advised respondents not to include any personal or business identifiers.

Response falls short

Forty-two responses were received. Participants strongly agreed that workplace exposure limits should be established for reproductive toxins. With regards to who should establish these limits, ACGIH received a mean score of 9.1 (on a scale 1-10) followed by NIOSH and the WHO with mean scores of 8.3 and 8.2, respectively. The EPA (2.7), union (2.5), and insurance company (2.2) were at the low end of the scale.

The response rate was less than expected, since the questionnaire was sent to a named TRI public contact for each employer known to release reproductive toxins to the air.

Any research project unearths other questions worth asking. For example:

  • Research should be conducted to determine the qualifications or credentials of TRI public contacts. EPA does not specify qualifications for TRI public contacts. It’s reasonable to assume that all public contacts must possess some EHS knowledge, but how much is not known.

  • Awareness and concerns about reproductive toxins could be affected by whether TRI contacts are male or female, or a parent. This would be interesting to know, too.

  • Awareness and concern might also be influenced by “population of employees that are or may become pregnant.” It would be interesting to learn if higher levels of risk awareness correlate to certain workforce demographics.

  • Finally, what is the effect of media coverage on awareness levels? Beginning in late 2004, NBC Today Show and CNN Headline News examined environmental exposures to pregnant women. Follow-up research could capture the influence of such reporting.

    Feeding a craving

    Most student researchers crave the opportunity to present our research beyond faculty advisors and some fellow students. I am very thankful to ISHN for allowing me to present a summary of my research to you.

    If you would like to respond to the questionnaire let me know. The research would be better with your input. Who do you think should establish these limits? Also, if you represent an organization that would like to see this research expanded, and perhaps could contribute administrative or financial support, please contact me at

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