The hazard? Surface contamination. More precisely, Curtis is talking about workers' dermal exposures to toxic substances--thousands of chemicals posing risk of ingestion, absorption or skin irritation--that accumulate on work benches, floors, equipment, tools, table tops, or innumerable other work surfaces.
"For 25 years OSHA has misguided the industrial hygiene community into focusing on air monitoring and overlooking what is possibly the greater hazard," says Curtis. "It's a travesty."
His radical sentiments are shared by others in the public health arena: Eileen Senn of the New Jersey Department of Environmental Protection says surface contamination has been neglected too long. "There's more and more recognition that air sampling is not enough," she says.
Tom Klingner, president of CLI Laboratories in Des Plaines, Ill., calls surface monitoring the "final frontier of industrial hygiene--the area where we'll be able to achieve the most dramatic reductions in occupational illnesses."
To that end, the fiscal year 1998 project plan for OSHA's Salt Lake Technical Center in Utah contains a wake-up call for industry, according to Curtis. Compliance officers will be instructed to pay closer attention to common surface hazards, like isocyanates, by taking surface samples during site inspections, Curtis says. Updated procedures and more efficient sampling tools will facilitate the process.
Where contaminants are detected and workers not properly protected, OSHA could cite employers under the personal protective equipment standard. (The rule requires employers to conduct hazard assessments and provide appropriate protective apparel. It does not mandate surface sampling.) Because there are no exposure limits for surface contamination, OSHA will proceed on a case-by-case basis, according to the agency's Deputy Director for Compliance, Richard Fairfax. But for any substance designated by OSHA's permissible exposure limit standard to be a skin irritant--and there are 142 of them--employers would be wise to conduct surface monitoring, maintain good housekeeping, and provide appropriate PPE, Curtis says.
Fairfax is careful to point out that no new enforcement policies or compliance decisions are being made on surface contaminants. He says inspectors have always considered surface contamination and taken wipe samples when necessary. Surface sampling is nothing new to the agency. But it could become a bigger priority. "For years it's been our policy that if there's a skin notation for a substance we can cite employers for exposing people without appropriate protective equipment. But, frankly, there hasn't been a lot of direction given to compliance officers in the past, and there are not many citations issued in this area," Curtis says.
He'd like to see employers and industrial hygienists pay closer attention to surface contaminants. Putting OSHA inspectors on their trail is one way to motivate them.
Scramble for guidanceThis news is likely to have employers and safety professionals scrambling for information.
Up to now, the only instruction OSHA has given employers on surface contamination is to keep work surfaces "as clean as practicable." With no recognized safe levels for surface contaminants like the permissible exposure limits for airborne hazards, or guidance for taking surface samples, many employers are likely to be at a loss. Only the most thorough chemical manufacturers, or work sites covered by Department of Housing and Urban Development rules on lead and EPA rules on PCB contamination, have surface monitoring programs in place, according to experts.
Industrial hygienist Eric Botnick, director at Free-Col Laboratories in Meadeville, Pa., says his lab rarely comes across employers conducting wipe sampling for substances other than lead and PCBs. In four years Botnick can't remember processing more than four requests for surface sample analysis.
Some employers dismiss surface sampling on legal advice. The logic goes, "Why collect evidence of exposures if there's no guidance on what to do about it?"
"Sometimes, more information is not what an employer wants," says Michael Green, an associate in the environmental/toxic tort department of the Philadelphia law firm Margolis Edelstein. "Documenting the presence of a contaminant may leave an employer susceptible to a 'failure to warn' lawsuit," Green says.
An OSHA source speaking not for attribution says he's heard that concern from employers before. But he questions what's riskier from a legal standpoint--"being able to do something and not doing it, or collecting data that could incriminate you?"
What's bad about the argument against sampling, "is that in some courts it's been argued that reasonable knowledge would require testing," says industrial hygiene and safety consultant Kenn White, president of Consultive Services in Virginia Beach, Va.
Green says, "Employers make the 'OSHA doesn't require it' argument all the time. It's a defense, but not an absolute one." To be sure, if OSHA begins its own surface sampling campaign, that defense will go out the window.
Fickle science?Another argument against surface sampling is that it is an imprecise science. It's true that methods and results can vary depending on the surface being sampled, or the media used to collect the sample. "You're never sure you got everything off the surface," says Botnick. Rough or porous surfaces like concrete or carpeting pose problems, he says.
And after a sample is collected, what to make of it is an employer's best guess. "Once you've got a measurement, what does it mean?" asks health physicist Terry Liaboe. "Does it represent a risk, or is it a number that may or may not mean anything?"
An official in OSHA's health standards office says he was impressed once by a worksite that had set its own surface exposure limits. The criteria? Whatever they were comfortable with. "It would be useful for someone to come up with a guidance document," he admits.
But complying with numbers should not be the point, says Klingner, whose company, CLI Laboratories, manufactures colorimetric surface sampling pads now being used in some OSHA inspections. "The original purpose of industrial hygiene was to reduce exposures," says Klingner. "We don't need exact numbers, we need exposure reduction."
Statistics indeed indicate that dermal exposures are getting out of hand. Occupational skin diseases, mostly in the form of allergic and irritant contact dermatitis, are the second most common type of occupational disease in the U.S., according to the Bureau of Labor Statistics. And the problem is worsening, BLS records indicate: between 1983 and 1994 the rate of occupational skin diseases increased from 64 to 81 cases per 100,000 U.S. workers.
According to the NIOSH National Exposure Survey database, as many as 13.2 million workers are potentially exposed to skin hazard chemicals in the U.S. Few industries are without dermal hazards, NIOSH says.
What you can doWill OSHA's new attention to surface contaminants demand that you conduct surface sampling? Not exactly. The PEL standard doesn't mandate air monitoring, after all. But there's no better way than air sampling for employers with hazardous processes to check their own compliance with the PELs.
How, then, can you determine whether your plant is a candidate for a surface monitoring program?
For starters, if your worksite harbors any substance withh an OSHA permissible exposure limit that includes a skin notation (a footnote indicating that the substance is a skin irritant or sensitizer) you're a target for an OSHA compliance officer with a swipe pad confirming compliance with the PPE standard, according to Curtis.
But even chemicals without skin notations could be candidates for surface sampling. "OSHA did not designate hydrochloric acid with a skin notation because it has a direct effect on the skin, not a systemic effect," points out Klingner. "And obviously that's a substance for which surface sampling would be indicated," he says.
You might also consider searching OSHA's Computer-ized Information System which lists substances with a potential for ingestion toxicity, skin absorption, or a hazardous effect on skin. (Search for the OCIS Chemical Sampling Information document at www.osha-slc.gov under "OSHA technical links.")
Other chemical databases list more than 3,000 chemicals that are skin irritants or sensitizers, says Klingner.
According to Curtis, the agency will eventually post information and guidance on surface sampling on its Internet site. Eileen Senn predicts there will be more interest in setting exposure numbers as employers become more aware of the risks surface contaminants pose.
But for now, sampling simply for the presence of contaminants, rather than a quantity, is the route employers and OSHA will likely go. Explains Kenn White, "You might not swipe the whole surface or even a representative part of the whole surface, but you run across a lunch table top, or bench top making the assumption that what you're looking for should not ordinarily be found on that surface. It's quite a discovery if you're not expecting it and a whole load shows up."