Obsolete OELs are bad business
Employees have access to more information than ever before, which raises an important question: How many of your occupational exposure limits (OELs) are out of date?
“We like to think that OELs are clear communications of the risk. They take a lot of information about the chemicals and boil it down,” said John Mikan, CEO of Experien Systems, during a session “OELs as the Ultimate Product Risk Management Tool: A Call to Action,” at Stewardship 2015.
But of the OELs adopted by OSHA in 1971, only about 30 have been updated, said Mikan. A number of other organizations have developed OELs, but the chemicals concerned are limited and updated infrequently as well. “What we really don’t know is how good those values still are,” said Mikan. In other cases, workers are handling chemicals without OELs, and “we haven’t really done a good look at what substances don’t have OELs that we really need OELs for,” he said.
The bottom line, said Mikan, is that workers have access to more information than ever before, meaning they will continue to have questions about exposure to hazardous substances. It’s an opportunity for industry to support the development of OELs, perhaps even developing their own at the chemical manufacturer and supplier level.
Manufacturers and suppliers resist developing their own OELs out of fear that it opens them to liability or because of the competitive disadvantage if competitors don’t have limits (or have higher limits). On the other hand, Mikan asked, what happens if manufacturers and suppliers continue to use obsolete or no OELs when they know better information exists? “Is the status quo good enough? If there is no OEL available, but the manufacturer knew it could be unsafe, can they be held liable,” he asked.
Mikan suggested that product stewards communicate the challenge to management and offer to facilitate a review of the company’s product portfolio. At the same time, work closely with industrial hygienists, who should communicate the need for OELs within the organization and to suppliers.
Not every chemical needs an OEL, so Mikan recommended prioritizing in this order:
Priority 1: Volatile or dusty GHS Cat. 1 carcinogens with no OEL or where the OEL doesn’t recognized it as a carcinogen.
Priority 2: Volatile or dusty GHS Cat. 1 mutagens, reproductive toxins, or target organ toxicants with no OEL or where the OEL was developed prior to data being available.
Priority 3: Volatile or dusty GHS Cat. 2 carcinogens, mutagens, reproductive toxins or target organ toxicants with no OELs or old OELs.
“We need to do better in terms of occupational exposure limits,” Mikan
Source: American Industrial Hygiene Association Product Stewardship Society www.productstewards.org