An industrial hygienist's perspective on generic standards

Our plain-English summary of An industrial hygienist's perspective on generic standards, by J.S. Lee (Annals of the New York Academy of Sciences, 1989).

The study

• Author: J.S. Lee
• Journal: Annals of the New York Academy of Sciences
• Published: 1989;572:93-9; discussion 107-9
• Read it: PubMed · Publisher

Abstract

OSHA and EPA regulations promulgated to date contain the necessary framework to consider generic standards in the 1990s. Missing in OSHA standards has been the requirement for a competent person to define and manage an occupational health program and the requirement for all employers who have toxic materials with significant exposures to have a basic occupational health program. Certainly we have evolved to a point where every worker significantly exposed to toxic materials has a right to know what that exposure is. Fundamental to generic standards is the need to define what is meant by toxic substance and significant exposure level. It is suggested that NIOSH maintain a list of recognized safe exposure levels that have been recommended by credible organizations including NIOSH. It is suggested that action levels be defined as one-half the lowest recognized safe exposure level. It is proposed that all employers be required to conduct an initial inspection of their workplace, using competent persons, to determine if exposures exceed action levels. This is only one step beyond the requirements of the OSHA Hazard Communication Rule which requires that employers identify and maintain a list of all hazardous materials known to be present in the workplace and to inform workers of the hazards. If exposure levels are found in excess of action levels, then the basic elements of current standards would be required, including regular employee-exposure monitoring, medical surveillance, sanitation, training and education, and a management plan.

In plain English

This article is a commentary, not a research study. No workers, patients or measurements were studied. The author, an industrial hygienist, argued that 1990s workplace regulation should concentrate mainly on "generic" standards for toxic materials in general, while keeping a way to add substance-specific requirements where appropriate. The author pointed to asbestos rules as precedents. The Asbestos Hazard Emergency Response Act of 1986 (AHERA) required school districts to inspect buildings for asbestos-containing material using accredited individuals. The 1986 OSHA Asbestos Construction Standard was OSHA's first to require a "competent person." The author proposed that NIOSH publish a list of recognized safe exposure levels. "Significant exposure" would mean exposure above one half of the lowest such level, called the action level. Each employer would have a competent person, at minimum a trained industrial hygienist, inspect the workplace. Where exposures exceeded action levels, the employer would provide monitoring at intervals of no more than 6 months, medical examinations at no charge, sanitation, training, and a management plan that put engineering controls before respirators. The author acknowledged the proposal could overwhelm current occupational health resources and suggested phasing it in.

We wrote this plain-English summary from the full article with the help of AI, and a second AI model checked each sentence against the article. It is not the authors' wording; the abstract and the article are their own account.

What the study did and found

• Design: Commentary or policy perspective (an opinion article proposing regulatory approaches); not an original research study
• Who was studied: No people or workplaces were studied. The article discusses U.S. OSHA and EPA regulatory history and proposals.
• Exposure: Toxic materials in the workplace in general. Asbestos regulations (AHERA and the OSHA Asbestos Construction Standard) are discussed as precedents; no specific fiber types are discussed.
• Main results:
  • The author argued that the 1990s warranted primary concentration on generic standards, without abandoning a mechanism for supplementary substance-specific requirements where appropriate.
  • The author described AHERA, the asbestos law for schools, as offering lessons for broader generic standards.
  • The author noted that the OSHA Asbestos Construction Standard (effective July 21, 1986) was the first OSHA standard to require a competent person.
  • The author proposed that NIOSH regularly publish a listing of recognized safe exposure levels.
  • The author proposed defining significant exposure (the action level) as exposure above one half the lowest recognized safe exposure level.
  • The author proposed that every employer be required to conduct an initial workplace inspection using a competent person, who at minimum should be a trained industrial hygienist.
  • Where exposures exceed action levels, the author proposed periodic monitoring with sampling intervals of no more than 6 months.
  • The author proposed that medical examinations be offered at no charge to employees exposed above action levels.
  • The author proposed a management plan in which engineering controls are used before reliance on respiratory protection.
  • The author proposed that employers not be required to reduce exposures unless those exposures exceed established PELs (Permissible Exposure Limits).
• The authors' conclusion: The author concluded that 1990s regulation should first define significant exposure. It should then propose a generic standard (or standards) relying on a competent person and requiring initial inspection, exposure monitoring, medical surveillance, sanitation, training, and a management plan. The author stated that the time was opportune to promulgate such standards.
• Limitations the authors state:
  • The author acknowledged that the proposal could overwhelm current occupational health and industrial hygiene resources, and suggested a phase-in starting with larger employers.

Topics

Medical terms in this study, explained in our Lexicon: OSHA, Competent Person, NIOSH.

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• Asbestos and disease: an industrial hygienist's perspective — M. Corn (1986)
• Re: Historical reasons for attitudes and opinions regarding asbestos and cancer, 1934-1965 — M. Corn, J.K. Corn (1993)
• Technological feasibility of the 2 fibers/cc asbestos standard in asbestos textile facilities — R.A. Curtis, P.H. Bierbaum (1975)
• Implementation of the federal asbestos standard in Connecticut — J.B. Schoenberg, C.A. Mitchell (1974)

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