MANAGING BEST PRACTICES: How good are your exposure records?
Why? For one reason, OSHA's air contaminants standard (29 CFR 1910.1000) states: "Any equipment and/or technical measures used for (controlling employee exposure to chemical hazards) must be approved for each particular use by a competent industrial hygienist or other technically qualified person." The language in the standard is not advisory and since the term "other technically qualified person" is not defined, strict compliance with the standard means ensuring the services of a competent industrial hygienist.
While industrial hygiene, safety and environmental functions are continually being blended into one job, you should be wary of applying the title "industrial hygienist" to anyone. Just like a few courses in first aid would not qualify someone as an occupational health nurse, neither should a few courses in industrial hygiene qualify someone to earn the title "industrial hygienist."
No simple choreNowhere is the need for an industrial hygienist more evident than in creating and maintaining industrial hygiene records. These include collection and analytical methodologies, calculations and other background data relevant to interpreting workplace measurements for a toxic substance; biological monitoring results; material safety data sheets; and chemical inventories.
IH records are more than just a legacy of what has happened. They may be used to interpret and predict what might happen in terms of future work-related illnesses.
OSHA's access to employee exposure and medical records standard requires that IH exposure records be maintained for not less than 30 years. Substance-specific standards such as lead extend this period to 40 or more years. IH exposure records have long retention periods because they are intended for use in epidemiology studies where the latent period for some diseases may be decades.
Employer IH exposure records represent the largest chemical exposure database in our nation. Eventually this data may be collectively and routinely mined to help determine if selected chemical exposures contribute to or cause particular illnesses and diseases not only among employees at one work site, but across an industry or within other populations.
The likelihood that this may happen continues to get stronger. The Nationwide Health Tracking Act of 2002 (S. 2054, H.R. 4061) was introduced this past March. This new legislation is designed to track the distribution of chronic diseases and their possible links to environmental factors - and researchers may find value in looking at IH records among local employers.
IH records are specifically accessible to current and former employees, representatives of deceased employees, designated employee representatives, collective bargaining units and OSHA personnel. They may also be accessed for discovery by legal representatives or by government researchers.
Who's competent?Broad access, long retention periods and the uncertain use of IH records underscore why a person truly fitting the title of industrial hygienist should be responsible for creating and maintaining these records.
But with few exceptions, anyone can call themselves an industrial hygienist. Perhaps this is why OSHA specifies the use of a "competent" industrial hygienist in its air contaminants standard.
There are several ways to determine who may be a competent industrial hygienist:
Is the individual a full member in a professional industrial hygiene association such as the American Industrial Hygiene Association or the American Conference of Governmental Industrial Hygienists?
Has the individual achieved certification as an industrial hygienist by a certifying body such as the American Board of Industrial Hygiene? The highest certification level is the Certified Industrial Hygienist (CIH).
A competent industrial hygienist, preferably a CIH, should perform the following minimum services for an employer:
1) Provide periodic onsite audits of the workplace to recognize existing and potential health hazards;
2) Establish and oversee an industrial hygiene monitoring program that effectively evaluates employee exposure to health hazards; and,
3) Specify administrative, engineering and other controls that protect employees from workplace health hazards.
Other than the periodic onsite audit, an industrial hygienist does not need to directly carry out the above industrial hygiene functions. Other personnel can accomplish these tasks at the direction of the industrial hygienist. Any reports or exposure monitoring data that may reasonably be expected to become subject to an epidemiology study or litigation should be reviewed and "signed-off" by a CIH.
Industrial hygienists should also participate in annual planning for a work site's overall environmental health and safety program, review and contribute to training on health hazards, assist in developing and upgrading written health programs (such as hazard communication), and be an advisor to other issues and concerns that may benefit from involvement by a competent industrial hygienist.
Valuable relationshipsIt pays to establish a long-term relationship with preferably one industrial hygienist, either a consultant or staff employee. That's because there is a steep learning curve that every industrial hygienist must go through to thoroughly understand the chemistry, toxicology or unique health hazards that might exist in your production and work processes.
Every three to five years, a third-party CIH should be contracted to review and report on the major functions and findings of your facility's industrial hygiene program. This verifies the integrity of your industrial hygiene activities.
Illness and disease are often caused by subtle and complex exposures to health hazards that require an educated and skilled mind to detect, evaluate and control. This is the domain of a competent industrial hygienist - not someone who may just know how to perform some industrial hygiene functions.