Work Practice Simulation

A work practice simulation is a study in which people reproduce a task, such as sanding joint compound, cutting asbestos-cement pipe or grinding brake shoes, using original or replica products while air samples are taken. The aim is to estimate how much asbestos a worker doing that task would have breathed.

Origin

Simulations became common in asbestos litigation from the 1980s onward, as the people and workplaces of earlier decades were gone and few real-time measurements existed. Both plaintiffs and defendants commission them, and many have been published in scientific journals.

Significance in Asbestos Context

When there are no air samples from the actual job, a simulation can give a judge or jury a measured estimate of exposure from a specific product and task. Results can be powerful: a simulation showing high fiber levels from mixing dry joint compound or blowing out a brake drum supports causation, while one showing low levels may be offered to argue that exposure was trivial. Because so much depends on how the study was set up, experts examine the details: whether the product was authentic and of the right era, whether the tools, room size, ventilation and duration matched the real work, whether cleanup was included, and who funded the study. Courts differ on whether a particular simulation is reliable enough to admit, and that question is often argued before trial.

Example Sentence

The defense offered a work practice simulation of brake replacement in a large, ventilated garage, and the plaintiff's expert pointed out that the real work was done in a small, closed one-car garage.

Related Terms

Exposure Reconstruction, Personal Breathing Zone Sample, Friction Products, Joint Compound, Fiber Release, Daubert Standard, Product Identification

Notes

• Describe your actual work in as much detail as you can: room size, ventilation, tools, how often, how long, and how you cleaned up.
• Ask who paid for any simulation offered in your case and how closely it matched your conditions.
• Old photographs of your workplace, garage or tools can help an expert judge whether a simulation is realistic.