Dispatch from China: Q&A with Victor Liu

Victor Liu, PhD, CIH, CSP, has worked as a consultant in China for the past two-and-one-half years.

Who have you been working for in China?

Contract manufacturers of U.S. companies and multinational corporations mainly. I don’t work with wholly-owned Chinese companies.

What type of EHS work do you provide?

Environmental health and safety program management training, auditing, and exposure assessment.

What are the major differences you see between how multinational factories practice EHS compared to Chinese-owned operations?

Multinational factories follow both China’s EHS requirements and their corporations’ EHS policy and requirements. Local factories doing business with foreign buyers are more interested in establishing and implementing EHS management systems.

Workers tend to be more passive in terms of EHS activities. It seems that the workers will need to be trained more in order to become active partners in EHS.

Quality of safeguards and PPE need to be improved.

How is PPE purchased in China?

Multinationals that I have worked with allow local plant managers to make PPE buying decisions. Chinese-owned operations do use PPE. The quality of the PPE is improving. The use of PPE in Chinese factories varies. Some use PPE made in the U.S. and some use PPE made in China.

What are the most significant improvements you’ve seen in Chinese EHS in the 2.5 years you've been working there?

The Chinese government is making significant progress in EHS legislation. However, there needs to be more enforcement and training of EHS professionals.

What are the most significant barriers to further safety and health improvements for Chinese workers?

The training of EHS professionals and enforcement.

At the factory level in China, regardless of foreign or domestic ownership, are safety and health duties handled by Chinese nationals?

Yes, safety and health duties are carried out by Chinese nationals.

What can a U.S. safety and health pro do to help improve safety and health in China?

Encourage buyers to require their Chinese business partners to implement EHS programs in their contracts and conduct EHS audits.

Any other comments regarding the state of EHS in China in 2008?

The situation is improving because the Chinese government is putting more emphasis on EHS. They recognize the need for EHS improvements and the difficulty in enforcing the EHS regulations in industries located in small towns and villages.

Victor Liu presented at the 2007 Sino-U.S. Occupational Health Workshop in Beijing, sponsored by the China Occupational Safety and Health Association, the American Industrial Hygiene Association, and the National Institute of Occupational Health and Poison Control, Chinese Center for Disease Control and Prevention.

Dispatch from Russia: Reducing the frequency and “heaviness” of injuries

By Boris Plastinin

In regard to the situation in the Russian Federation’s metallurgical industry in the XXI century, the following is noteworthy: steel output grew from 60 million (2001) to 72.4 million (2007) increasing by seven to nine percent a year.

The steel work has been modernised and a lot of up-to-date plant units – such as blast furnaces, continuous casting machines, vacuum vessels etc. – have been put into operation. Using Martin furnaces and moulds was reduced considerably. Some plants were under reconstruction, their subsidiaries were cut out, and as a result there was approximately a 50 percent staff cut down (Magnitogorsk metallurgical plant, West Siberia metallurgical plant, Novokuznetzk metallurgical plant). Several enterprises are run by new owners (Yevrazholding, Mechel, the Urals steel).

These positive changes enabled us to increase working productivity in the metallurgical industry. But we are still behind leading industrial countries. The average Russian metallurgical plant employs some 5,000 workers to produce 1,000,000 tons of steel. Even Magnitogorsk metallurgical plant, which is the leader in the branch, employs some 2,000 workers to produce one million tons of steel, in spite of all restructuring measures. Meanwhile, our American competitors only employ 300 workers and China metallurgical companies could do with 700 workers to produce one million tons of steel.

The production rise as well as removing old plant units and organizing proper work of personnel departments influenced labour safety in industry and made it possible to reduce the number of traumatic cases.

Safety statistics
With the constant decreasing of the number of employees in the metallurgical industry from 1.2 million in 2000 to 922,000 in 2007, the number of accidents decreased from 4,312 in 2000 to 2,114 in 2007. The number of lethal accidents decreased from 195 in 2000 to 120 in 2007.

During the past several years the number of heavy accidents has been on the decrease as well. From 2001 to 2004 there were about 600 heavy and lethal accidents a year. In 2005 this factor began to change for the better, and in 2007 there were 398 heavy and lethal accidents, that is the number lessened 1.5 times.

The frequency factor (Kf – the number of accidents per 1,000 employees) changed from 3.6 (2000) to 2.3 (2005-2007). At the same time the heaviness factor (Kh – days on sick leave per one accident) was growing during the period: 33 days in 2000 and 50 days in 2007. The frequency factor for lethal accidents decreased from 0.163 (2000) to 0.13 (2007).

Who gets injured and why
The analyses showed what had caused the accidents to happen:
  • 62-70 percent - breaking labour safety instructions by administration;
  • 70+ percent - breaking labour safety instructions by employees;
  • 30-40 percent - breaking labour safety instructions by strangers;
  • 25 percent - working in dangerous areas near the equipment. It was determined that as many as 80 percent of the accidents had happened because of ill-management and 20 percent had been caused by technical problems.
The following working operations bear most accidents during the technological cycle:
  • repairing and installing (up to 30 percent);
  • transportation (up to 22 percent);
  • operating the equipment (up to 30 percent);
  • lifting and shipping (up to 20 percent).
In the Russian Federation the frequency factor for lethal accidents in the metallurgical industry is similar to Russia’s national average, though metallurgical plants are considered to be dangerous industrial sites. For example, the situation in Japan is different: the frequency factor is 45 people per 1,000,000 employees and the average is 20 people per 1,000,000 employees, that is 2.25 times less than the one in the Russian Federation. From 1998 to 2003 in China the frequency factor for lethal accidents varied from 40 to 54 people per 1,000,000 employees.

Prevention recommendations
To reduce the number of accidents the labour safety departments and industrial safety departments should consider the following preventive measures:
  • use of remanufacturing, re-equipment and automation instead of manual work and consequently removing a lot of workers from dangerous industrial areas;
  • equipment to be installed should meet specification requirements and it should be examined and tested by qualified experts;
  • reconstructing old buildings, structures, communication systems and dangerous units;
  • use analytics and new information technologies in the metallurgical industry.
Today, 20 metallurgical and mining enterprises are involved in a new programme. The enterprises are to send annual and quarterly reports and inform each other about accidents, and under what circumstances they happened. Every year from 50 to 60 letters are usually sent. They provide workers with useful information and help them avoid bad accidents.

In addition, the work of personnel departments should be examined and improved (instructing, training, practising, informing about injuries, accidents, damages and possible risks).

Education should be of higher quality. Present education is too formal and because of the lack of individual worker education there are a lot of shortcomings causing accidents during the production process (working in dangerous areas near equipment, insufficient co-operating and so on).

Accidents usually happen to people who are engaged in repair work or work for contracting organisations. Labour safety requirements for such firms should be adjusted to standard requirements for metallurgical enterprises.

One can see a positive tendency to reducing the number of heavy accidents and lethal accidents, better working conditions and modernisation in the process. So there is a big hope. Provided that stable and task-oriented work of labour safety departments and industrial safety departments make the situation better, the frequency factor for lethal accidents may be expected to fall to 0.07-0.08 in five or seven years.

Boris Plastinin is general director of the Research Institute for Labour and Safety in Metallurgy. He is a professor at the Department of Life and Safety in the South Ural State University, and possesses a doctoral degree in engineering science. He can be contacted at e-mail: niitb@chel.com.ru; phone: +7 +(351) 724-70-44

Dispatch from VIETNAM: Urbanization comes at the price of worker safety

By Roy Little

Since instituting the Doi Moi economic reforms in 1986, Vietnam, a nation of 86 million with nearly 40 million in the workplace, has experienced tremendous growth and urbanization. Its entry into the World Trade Organization has resulted in an astounding quadrupling of foreign direct investment and the accelerated equitization of state-owned enterprises. Its economy continues to surge at 8-12 percent GDP, and there is a huge demand for construction of hotels, schools, hospitals, and other basic infrastructure.

Employers ignore regulations
Coming from impoverished rural areas, the poorly educated labor force hired to meet these demands faces low wages and extremely hazardous working conditions. Despite national legislation and decrees that have attempted to address both employer and employee safety responsibilities and rights, there is virtually no enforcement of regulations. This is due, in part, to a shortage of qualified government safety inspectors as well as rampant corruption. The willful non-compliance of employers results in the death of an estimated 17,000 annually and leads to countless work-related illnesses and disabilities.

Although required to do so by law, few if any employers report injuries or deaths, and there are no consequences for employer negligence. This lack of enforcement and consequences, coupled with an overall moral bankruptcy, permeates every aspect of Vietnamese society.

Yes, this is a Third World country that remains uncivilized in many respects.

My own observations corroborate government statistics citing the most serious safety deficits occurring at constructions sites, sites using high-voltage electricity and at mining operations.

With the exception of hard hats, personal protective equipment is completely absent at most job sites; the usual worker wears sandals and has no gloves, eye protection, fall protection or respiratory protection, and certainly no training.

The electrical system is frequently a nightmare with hot wires hanging over sidewalks and streets. Nobody knows what wire is for what. New wiring is put in place while the old remains, there are no enclosures for circuit hardware, there is no labeling, and circuits and enclosures are often ungrounded. Mining operations are unlicensed and operated by anyone who has equipment. The equipment is not maintained, and there is seldom a maintenance program anywhere in any industry.

Western companies address unsafe conditions
In contrast, American, Japanese, Australian and European enterprises operating in Vietnam have brought with them their safety policies, and, as a result, jobs with these companies are highly sought after.

Corporations such as Conoco-Phillips, International SOS, and Intel are now organizing an NGO (non-governmental organization) in Ho Chi Minh City to address workplace safety. Plus, these Western companies require all suppliers in the supply chain to have safety programs in place or they will not do business with them. Although these multinational companies typically have well-developed safety and health management systems, they often place local Vietnamese into safety management positions for which they are unqualified. While there is an increase in positions advertised for safety officers, these jobs don’t require experience or education in safety and health – only “an interest in safety.”

A local university program in labor safety has 80 undergraduates enrolled, but the quality and content of the program is weak due to unqualified instructors.

One of the greatest challenges, therefore, is to develop a mindset in managers and local safety officers that safety is a priority that can no longer be ignored.

Challenging the status quo
Because most state-owned and local enterprises have no safety plan in place and see little reason for change, the first challenge is to address values, attitudes and beliefs.

A client recently asked me to conduct training sessions for senior managers about how safety programs might benefit their bottom line. Predictably, the general director was very interested in increased profitability and not particularly interested in establishing a comprehensive safety program. Despite this disappointing response, initial contacts like this one are still an important step leading to opportunities for change.

“We have to start somewhere”
The situation will remain overwhelming if we allow it to. When asked about the Vietnamese lack of commitment to basic health and safety standards, a safety manager at Conoco-Philips said simply, “We have to start somewhere.”

Western corporations and individuals with conviction must indeed “start somewhere” if the Vietnamese workforce is ever going to enjoy appropriate health and safety standards.

Roy Little is originally from Minnesota, where he worked primarily in the open-pit taconite mining industry for 26 years. As an employee of LTV Steel, he worked as a laborer and later as a locomotive engineer, equipment operator, electrician, mine and railroad operations supervisor, train dispatcher, and maintenance planner. Upon retirement, he relocated to Vietnam to become a teacher of English and business. After seeing a great need, he earned credentials and became a Safety Trainer and Safety Consultant in Ho Chi Minh City. He has a B.S. degree in applied psychology and graduate work in human performance improvement. His safety certifications come from the International Association of Safety Professionals in Washington, D.C.

Dispatch from EUROPE: Scrambling to REACH pre-registration deadlines

By Sean Mahar, Ph.D.

REACH, the Registration, Evaluation and Authorisation of CHemicals regulation is now a year old and causing a mad scramble of preparation for American EHS professionals.

REACH introduces an obligation to send a registration to the European Chemicals Agency (ECHA) for chemical substances on their own or in preparations that are manufactured in or imported into the European Union (EU) in quantities of one tonne or more per year. The obligation also applies in certain cases to substances in articles. Failure to register bars a company from manufacturing the substance in the EU, or importing it into the EU.

Pre-registration occurs from June 1st until December 1st of this year. This is an important window not to be missed. It allows companies to benefit from extended registration deadlines (2010, 2013 and 2018) depending on the substances involved and their volumes. Pre-registration is applicable to “phase-in” substances, essentially substances requiring registration already being imported into the EU.

Here are steps involved in the process:
  1. Pre-registration is free and calls for submitting the name of the substance with its EINECS and CAS numbers, the name and contact information of the registrant, the envisaged deadline for registration and the expected tonnage.
  2. Also required, if applicable, are the names of substances with similar properties that can be used to facilitate the risk assessment of the substance, reducing the need for testing. The pre-registration file must be submitted electronically via the REACH-IT portal on the ECHA website. Failure to pre-register will require a full registration before importing the substance into the EU again.
  3. Only a natural or legal person established in the EU can be a registrant. Companies without a legal presence in the EU will have to have someone to register their substances on their behalf. This can be done by the importer of the substance or by an “only representative” (OR).

    An OR is “a legal entity established in the EU which has sufficient background in the practical handling of substances and the information related to them to be able to fulfil the obligations of importers.” The use of an OR will relieve importers in the supply chain from registration obligations and they will be regarded as downstream users of the OR.
  4. Gather information on the uses and properties of the substance and sharing information in a Substance Information Exchange Forum (SIEF). Each SIEF is organized on a pre-registered substance with the same chemical identity. The aims of the SIEF are to facilitate data sharing for the purposes of registration, and to agree on the classification and labeling of the substances concerned.
Plus, the SIEF is a platform for the joint submission of data, and an area for the exchange of the data needed to perform the Chemical Safety Assessment (CSA). Downstream Users (DU) and other stakeholders (Data Holders) can participate in a SIEF as well and share (or sell) relevant information.

The SIEF is not part of the ECHA. The onus is on industry to come together and organize. It’s expected that one participant will take the lead and serve as “SIEF Formation Facilitator.”

The facilitator position isn’t listed in the REACH regulation, but a “Lead Registrant” is. It’s expected that the facilitator will serve to organize the data exchange and become the Lead Registrant, who will then lead the preparation of a joint submission for registration.

Within the SIEF are two main categories of participants: “Potential Registrants” and “Data Holders.”

Potential Registrants are those who have pre-registered a phase-in substance and include Manufacturers/Importers (M/I) and Only Representatives. A Third Party Representative can act as an “agent” for a M/I who can remain anonymous to the other stakeholders involved in the SIEF. The M/I remains the pre-registrant and is the party required to register. The Third Party Representative only has a role in the context of data sharing proceedings.

A Data Holder is anyone holding information relevant to a phase-in substance and willing to share it. They can request the ECHA to be a participant in the SIEF for that substance and provide information to other SIEF members.

Data Holders may include M/Is that are below the one tonne/year registration threshold, DUs and others with an interest, such as trade or industry associations, laboratories, government agencies, etc. Data Holders can only provide data to potential registrants of the SIEF and request cost sharing for the data supplied.

Formal registration
Registration follows and is a four-step process: gathering existing information, considering information needs, identifying information gaps and generating new information or a testing strategy in line with REACH obligations. We’ll cover those steps in future articles. For now the action items for American EHS professionals are:
  • identify what substances or substances in preparations or articles their companies import into the EU and pre-register them;
  • identify the volume band for each substance on its own or in a formulated product;
  • to ensure business continuity, identify the substances sourced from the EU to ensure they get pre-registered;
  • identify downstream uses for incorporation into Exposure Scenarios and Risk Management Measures;
  • prepare data for EU importers or Only Representative.
More information is available from the ECHA at its Web site (http://ec.europa.eu/echa).

Dr. Sean Mahar is an American EHS professional located in Europe. He has over 25 years experience in industry, academia and the military and is a principal in Euro Safety and Health, which offers industrial hygiene services in addition to REACH compliance and OR assistance. He has a Ph.D. from the University of Iowa in Environmental Health and Preventive Medicine.

Dispatch from Israel: Israel’s Occupational Health and Safety Program


Israel is small in land, to be sure, but large in technological and scientific accomplishments. Israel’s $100-billion economy is greater than all of its immediate neighbors combined and boasts more than 3,000 high-tech companies and startups.

It has the highest concentration of hi-tech companies in the world, apart from the Silicon Valley. The 60-year old country, made up of immigrants from all over the world, continues to grow at a staggering rate. Highways, neighborhoods, manufacturing facilities, businesses, hospitals and universities are being built every day – and along with them issues related to the environment, health, safety and well being of its citizens and workers.

Challenges of growth
The Israel Institute for Occupational Safety and Hygiene (IIOSH), the governmental body charged with promoting safety and hygiene in the workplace, has its work cut out for it.

New companies continue to sprout in the areas of biotech, semiconductors, nanotechnology and chemical manufacturing. Each industry has its own unique exposures to understand and monitor, such as potash, magnesium, phosphates and bromide with chemical manufacturing, and nanoparticles in the area of nanotechnology. Even more established industries, like agriculture, have their exposures, such as pesticides.

IIOSH has been in existence since 1954. It is comprised of ten departments, located at the IIOSH headquarters in Tel Aviv, and four regional branches. The institute employs roughly 113 professionals who are ultimately responsible for setting up committees within companies to ensure ongoing training and awareness of safety hazards in the workplace.

For example, IIOSH, jointly with other Israeli and international organizations, has conducted — mostly in English — a comprehensive training course for Palestinian engineers and physicians who were to be appointed labor inspectors in the Palestinian Authority. This program of professional collaboration, knowledge exchange, and outreach with Israel’s Arab neighbors is designed to further develop and contribute to safety, health and peace in the region.

The country as a whole has only about 70 professionals managing health and safety programs outside of IIOSH. This is surprising, considering Israel leads the world in the number of scientists and technicians in the workforce.

The Ministry of Labor and Ministry of Environment are the primary government agencies promulgating occupational safety and health related regulations. Regulations span a wide variety of categories including hazard communication, physical safety, and chemical exposure.

While the number and breadth of regulations is robust, enforcement is spotty given the relatively few inspectors employed by the agencies. Still, for a country of its size and age, Israel has made remarkable progress.

Mark Katchen, CIH, is the managing principal of The Phylmar Group and is the American Industrial Hygiene Association’s Ambassador to Israel. Mark chairs the AIHA International Affairs Committee. Dr. Yami Yaffe is president of Yaffit Health & Safety in Israel.

Dispatch from INDIA: One man & many friends develop occupational hygiene in India


The need for occupational hygiene and safety in industries was overwhelmingly realized in my first job as a supervisor at a chemical manufacturing company in India in 1975 with a salary of U.S. $5/month. There were five fatalities and several cases of chemical poisoning during the first few days of my first job.

The interest in occupational safety and hygiene turned into a passion as I saw more workplaces in India with deplorable working conditions. A regulation requiring every factory with more than 1,000 employees to have safety officer was promulgated in the Indian Factories Act and qualifications for the safety officers were laid down in the Act. As a result, the company sponsored me for a 1.5 year Diploma in Industrial Safety (DIS) training program and gave me paid leave and also paid for all expenses.

A little bit of education in industrial hygiene occurred as one of the courses in DIS was on industrial hygiene. The desire to learn industrial hygiene grew so strong that I came to the U.S., obtained an MS in Occupational Safety at University of Cincinnati (UC) and later obtained my CSP and CIH.

Turning talk into action
During the early days of my career and later on the understanding developed within me that talking about deplorable working conditions and other issues will do no good, as opposed to doing something about it. As a result, after working in the U.S. for about 12 years, a decision was made to return to India to start India’s first Master in Industrial Hygiene (MIH) program. One of the important lessons I learned was this: I would not be able to start any MIH program in India without help from the USA.

Planting seeds
The seeds for the MIH program were planted when I met Dr. Scott Clark, a faculty from the MS in IH program at UC, at a motel near Philadelphia late night in 1996. Three universities in India were approached to explore if they would provide a birthplace for MIH program.

I was elated when an engineering collage dean and chairman of the trust running several colleges at Saradar Patel University (SPU) in Gujarat called me in U.S. and offered their support for the program. The SPU also made it clear that they would provide all support; however financial resources were limited.

At that point, I made a commitment to spend two years at the collage to start the program without taking any salary. The important challenge was how to get faculty support, books, publications, instruments; all at low or no cost, especially when student fees are about U.S. $500/year.

Building a network
Several meetings were held with the college administration, engineering college faculties, medial collage faculties, National Safety Council, National Institute of Health (NIOH) and industry representatives. The support of these institutions was pivotal in that it provided much needed visiting faculties in the core subjects of industrial hygiene.

At U.S. and international fronts, several meetings and communications were held with AIHA International Affairs Committee members, Australian Occupational Hygiene Association and fellow IH professionals. The support from international community was overwhelming. A truckload of books was donated by several institutions and individuals. Manufacturers of IH equipment donated air sampling equipment. The shipping cost for the books was paid for by a professional friend.

A Memorandum of Understanding was signed with University of Cincinnati and SPU for faculty exchange and other support. The UC curriculum of MS in IH program was modified to meet the country-specific priorities in India.

Taking off
In September 1997, India’s first MIH program was inaugurated. The first class of 12 students started their study in the MIH program.

An additional semester on safety courses was added and the program was called Master in Industrial Hygiene and Safety (MIHS). This addition was very much needed as industries were looking for IH professionals with background in safety also. With the addition of the safety courses, the MIHS program was recognized as an essential qualification for anyone to work as Safety Officer in industries as required in the Factories Act.

One decade is gone since the program started. All 78 graduated students are working in industries and institutions. Twelve more students will graduate this year. This would not have happened without unparallel commitment and contribution from SPU staff, Drs. Carol Rice and Scott Clark and generous financial donations from a number of individuals and institutions including Dr. Rick Fulwiler and AIHA.

I do not wish to take credit for sustaining this program as I am providing now limited support to the program and Amit and Shradhha, two committed faculty members are running the program.

Dr. Kalpana Balakrishnan, who graduated from John Hopkins, also returned to India and started one more post-graduate program in the southern part of India. Several companies conduct their own short-term IH training programs. We have been involved in conducting 22 applied IH training programs in six countries covering more than 600 employees of one corporation. These efforts will have a far-reaching impact in reducing health risk.

One of the most rewarding works in my life time was to start the MIHS program and to have a most gratifying experience of working with so many committed professionals around the world whose support is the reason we still have the program running.

Maharshi can be reached at maharshi.mehta@issehs.com