Which regs?We are trained to use applicable regulations as a starting point for any industrial hygiene project whether it is exposure monitoring or auditing, but you cannot assume that U.S. regulations and customs apply to other countries. While many countries model their IH-related regulations after OSHA and the American Conference of Governmental Industrial Hygienists (ACGIH), many nations have tailored the regs to meet their own specific needs or adopted OSHA and/or ACGIH regs years ago that are now outdated by U.S. standards.
There can also be different regulations and guidelines for different parts of the same country. Much like in the U.S., where states can adopt their own state-specific regs, such is the case in many other countries. For example in Canada, each province can have its own set of regulations, and many often do. It's important to know what province you're dealing with and what regulations apply to that province.
Finding infoSo how do you find out which regulations apply to the geographic region of the world you are dealing with? If the location has a regulatory authority that has jurisdiction of the workplace, such as a Ministry of Labor, this is an obvious first choice for seeking information. However, local universities and law firms can also be good sources of regulatory information.
Do not assume that even the most advanced countries have regulations, guidelines and best practices that are equal to those in the U.S. Even the most civilized and westernized nations often do not have regulations and guidelines that are as specific, detailed or restrictive as those in the U.S.
On the other hand, countries that we think of as less advanced might have more stringent regulations. Take, for example, Canada and asbestos. In the U.S., we consider asbestos a routine topic in industrial hygiene because of the great detail spelled out in our regulations for handling it. But Canadian asbestos regulations are not as elaborate and detailed. For example, rarely is it required that an air-tight enclosure be constructed for even large-scale asbestos removal projects.
U.S. standards elsewhere?It is natural for American industrial hygienists to want to apply U.S. regulations to other countries. We know the regs well, are accustomed to interpreting them, and have experience applying them successfully. Often-times it is difficult and time-consuming trying to track down and understand regulations in other countries since your familiar resources and networks are not at your fingertips like in the U.S.
Therefore, we tend to take a better-safe-than-sorry approach and apply what we already know to wherever we are. Furthermore, U.S.-based companies are challenged in the courts for not enforcing the more stringent U.S. standards to their facilities in other countries. So our lawyer friends would like for us to be able to apply U.S. standards to foreign operations as well.
Applying U.S. regs in a foreign country, however, is easier said than done. Let's take the Canadian asbestos example. Many asbestos contractors in Canada, particularly the smaller local ones, are not experienced at building elaborate air-tight enclosures and performing intricate glove bagging removals. What is second nature for most U.S. contractors is strange to many Canadian contractors. Thus when you change the specifications of the job, the cost and timing increases significantly. Furthermore, air-sampling data will often show that the less stringent methods are equally effective and more than adequate.
You'll have a tough time convincing the plant manager to change contractors and spend three times as much money to do less removal because . . . well, uh . . . OSHA says so. His or her response is likely to be "Who is OSHA and why do I care?"
Different lifestylesThe same principles apply to safety issues as well. Take, for example, a project I worked on in Singapore. Singapore is a very westernized and advanced country. The project involved exposure monitoring, environmental and biological sample analysis. Due to the highly hazardous nature of the project, we needed fast and accurate results.
Finding a lab in Singapore that could perform the analysis according to the same high level of technology that we are accustomed to in the States was fairly easy. This is not surprising given how technologically advanced most Asian countries are. Finding 24-hour turnaround for our results took a little more effort, but was feasible.
However, finding a lab where it was not uncommon for employees to work in shoes that do not provide complete coverage of the foot (i.e. toes and heels) was another story. Before you cringe at the thought, realize that in many parts of Asia it is their culture to go barefoot a great deal of the time and wear flip-flop sandals when shoes are called for. Except in industrial or construction settings, shoes that do not cover the toes and heels are acceptable footwear for most operations inside a building.
When in Rome. . .It is not a question of right or wrong, or who has the better standards. It is more a question of how to go about being most effective in whatever part of the world you are working. As occupational safety and health professionals, it is our job to ensure workers are adequately protected, but, like it or not, we must play by the rules.
In order to be effective, therefore, we must know what the rules are. So it is best to do your homework in advance and be familiar with the regulations and best practices that apply to the geographical region in which you are working. Approach projects with an open mind. The American way is not always the best way.
SIDEBAR: Speaking the languageIf you're an industrial hygienist working abroad, make sure you research the regulatory information for that region of the world well in advance of getting there since language barriers and translation can be a significant issue. Beware of literal translating services. These services provide a literal translation for a given fee, but a literal translation can often be misleading and does not always result in an accurate interpretation.
Just like in the U.S. we do not write as we speak, so it is in most other countries. Furthermore, you cannot assume that if you are dealing with an English-speaking country, you will not have language issues. In Europe, for example, while many people speak English they use words in a different context than we do, and their slang is different as well.