Catching employers, not terrorists
This month's article describes how an improved U.S. public health system, in response to terrorist concerns, may impact your EHS program.
Health trackingLast month's column (written before September 11) described the merits of a national network to track chronic diseases. Since September 11, the need and urgency for this type of system has taken on much greater importance.
The anthrax attacks demonstrate that a coordinated effort by the health community to quickly share health and medical information is critical to identify possible environmental sources for outbreaks of illness or disease.
Many hospitals, clinics and labs across the nation are voluntarily changing or adding procedures. A common question now: Where does a patient work? Health services are also freely exchanging information, even with competitors. These voluntary changes have already been credited with quickly identifying two confirmed cases of anthrax.
The government is also increasing funds to beef up our nation's public health defenses. For example, the House Appropriations Committee recommended a Fiscal Year '02 budget increase of nearly $3 billion dollars (from an initial budget proposal of about $25 billion) for the Centers for Disease Control (CDC) and National Institutes of Health. The budget specifically includes monies for initiating a national health-tracking network.
On the legislative front, the model Health, Environment, Assessment and Rapid Response and Tracking Act (The HEARRT Act) proposed earlier this year by The Trust for America's Health (www.healthyamerican.org) is receiving serious attention. National and state health and public interest groups officially supporting the HEARRT Act have tripled during the past few months.
Since September 11, California passed legislation for an environmental health surveillance system. State groups in Ohio, Pennsylvania, Wisconsin, Maryland, Louisiana and Florida have sent letters to their congressional delegates urging action on health tracking legislation.
Case Studies in Environmental Medicine (CSEM), used by primary care providers to understand hazards in the environment and help evaluate potentially exposed patients, now focus on illness and diseases, rather than individual chemical hazards, according to the U.S. Agency for Toxic Substances and Disease Registry (ATSDR), an arm of the CDC.
ATSDR recently published four new case studies under a pilot-testing program. The program - which urged industrial hygienists and other non-medical professionals to participate - was scheduled to conclude this past November. The new case studies are: (1) Responding to Disease Clusters; (2) Environmental Triggers of Asthma; (3) Children and Environmental Hazards; and, (4) Immunological Disorders. These four topics correspond to the "priority chronic diseases and conditions" cited in the proposed HEARRT Act.
EHS impactSo how does tracking community illness and disease impact EHS programs?
Trinity American Corporation in North Carolina is a good example. The company was "inappropriately" ordered to close after being cited as a "public health threat" under the emergency provisions of the Clean Air Act, according to an article in the September/October 2001 issue of the American Industrial Hygiene Association Journal (AIHAJ) by a University of Michigan author and others.
Children around the plant exhibited more asthma cases than expected and Trinity American processed toluene diisocyanate (TDI), which is known to induce asthma. But TDI and other chemical emissions from the plant "did not exceed any required or recommended concentration limit" at the plant fence line, according to the article.
Still, investigators from ATSDR concluded, "No scientifically plausible sources of the health problems other than emissions from the Trinity American Corporation have been identified," and the plant was ordered to close.
The lesson here? Simply being in compliance with emission limits and environmental rules may not be an adequate defense against claims that a plant is a public health threat. This is similar to employers not being shielded from a workers' compensation claim if an employee can demonstrate that he/she contracted an illness or disease resulting from or aggravated by work, even though chemical exposures were kept below legal and recommended limits.
Gaining momentumIt's clear that efforts to track illness and disease related to environmental factors are gaining steam. Like Trinity American, your EHS program could soon be measured against local community health outcomes. If illnesses or diseases among populations near your business exceed the expected norm, your plant operations might be part of epidemiological investigations. Review of your Toxic Release Inventory reports and other public EHS data will be an initial step in the process.
By strengthening the U.S. public health infrastructure to spot and defend against actions by terrorists, we might find that some American businesses could be harming public health. Some U.S. businesses might become casualties from "friendly fire."
"Even if the specter of chemical and biological terrorism did not loom large, our growing knowledge about the relationship between environmental exposures and human health justifies the action that the federal government is contemplating in the name of national security," said Donna Shalala, president of the University of Miami and former secretary for the Department of Health and Human Services, in an article in the October 10, 2001, Miami Herald.
From possible to probableWe must begin to realize that it is not only possible but probable that our plant operations might be subject to a community health investigation.
This probability is heightened by findings in the "The Ecology of Medical Care Revisited," published in the June 2001 issue of The New England Journal of Medicine. The article revisits a study conducted in 1961 regarding the number of people in a community who get sick each month and seek medical care. Policy-makers have used the original study as a framework for decisions about community health resources and educating doctors and other healthcare professionals for the past 40 years.
The updated study finds that for every 1,000 men, women and children in the U.S. on average each month: 800 will experience symptoms of illness; 327 consider seeking medical care; 217 visit a physician in the office; 13 receive care in an emergency department; and eight are hospitalized.
As I've tried to point out in this article, pressure is mounting for changes in our nation's public health system. And as an EHS professional, you could be caught in the middle. Are you sure your plant is not contributing to illness in the community? How should you respond? Start by considering the public health impact of your operations. Become familiar with the intent and purpose of the proposed HEARRT Act and by reading case studies from the ATSDR. Other ideas should flow from there.