How do you interpret regulations: through science or agency rules?

Our plain-English summary of How do you interpret regulations: through science or agency rules?, by J.H. Lange (Toxicology and Industrial Health, 2002).

The study

• Author: J.H. Lange
• Journal: Toxicology and Industrial Health
• Published: 2002;18(2):107-8
• Type of article: Comment, Letter
• Cited by: 5 articles, as counted by NIH iCite
• Read it: PubMed · Publisher

Summary of the article

This letter to the editor responded to a paper by Wallingford and Snyder (2001). That paper reported that asbestos exposures among workers cleaning up the World Trade Center (WTC) disaster site were below the OSHA permissible exposure limit of 0.1 f/cc as a time-weighted average, and that bulk asbestos samples did not represent a health hazard. In that study, air samples above the limit by phase contrast microscopy (PCM) were reanalyzed by transmission electron microscopy or a modified polarized light microscopy method. Three bulk samples exceeded 1% asbestos, with concentrations between 1 and 3%. The author noted that other studies of the WTC had reported higher exposure levels that were more widely distributed around the site. He argued that regulatory agencies interpret asbestos standards strictly when evaluating private parties but, for themselves, on the basis of economics, practicability and reasonableness, creating two regulatory schemes. He stated that the 1% definition of asbestos-containing material was apparently based on opinion rather than health standards. He also stated that the OSHA standard specifies only PCM, yet a modified PCM method was used at the WTC. He suggested that asbestos contributed to a mixture of exposures likely causing emerging health problems. He concluded that agencies should judge standards from a health-based perspective and adjust methods to current scientific thought.

PubMed has no abstract for this study, and the article doesn't print one. We wrote this summary from the full article with the help of AI. It is not the authors' wording.

In plain English

This was a letter to the editor reporting no new measurements, not a research study. The author responded to a 2001 article by Wallingford and Snyder on asbestos exposures of World Trade Center (WTC) cleanup workers. As the letter described it, that article reported exposures below OSHA's limit of 0.1 fibers per cubic centimeter (time-weighted average); samples exceeding it by phase contrast microscopy were reanalyzed by other methods. It reported three bulk samples of 1 to 3% asbestos and suggested no occupational asbestos hazard at the WTC. The author stated that other studies, including the author's own, reported higher and more widely distributed exposure levels. The author argued that agencies apply asbestos rules strictly to private parties but flexibly to themselves, citing a modified microscopy method used at the WTC. The author wrote that emerging health problems were unlikely directly related to asbestos but suggested, without data, that it contributed to a mixture of exposures likely causing them. The author concluded that regulatory agencies need to look at standards from a health-based perspective rather than through 'legislating of science'.

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: Letter to the editor (commentary on a previously published article); no original data
• Who was studied: No population was studied. The letter discussed an earlier article by Wallingford and Snyder (2001) on asbestos exposures of people doing cleanup at the World Trade Center disaster site.
• Exposure: Asbestos at the World Trade Center site, as reported by Wallingford and Snyder: airborne levels compared with the OSHA permissible exposure limit of 0.1 fibers per cc as a time-weighted average, and bulk samples
• Main results:
  • The letter itself reports no findings of its own. As the author describes it, Wallingford and Snyder's article suggested there was no occupational asbestos hazard at the WTC, with three bulk samples above 1% asbestos (ranging from 1 to 3%).
  • As the author describes it, samples in Wallingford and Snyder's article that were above the limit by phase contrast microscopy were reanalyzed using transmission electron microscopy or a modified (differential) polarized light microscopy.
  • The author stated that other WTC studies (Ilgren 2001 and the author's own work) reported higher and more widely distributed exposure levels, including in bulk samples.
  • The author argued that agencies interpret regulations strictly for private parties but, for themselves, on the basis of economics, practicability and reasonableness.
  • The author noted that OSHA's standard specifies phase contrast microscopy, but that a modified method was used at the WTC.
  • The author wrote that health problems emerging after the disaster were unlikely to be directly related to asbestos exposure, but suggested, without presenting data, that asbestos contributed to a mixture effect likely causing them.
• The authors' conclusion: The author concluded that regulatory agencies need to look at standards from a health-based perspective and not through 'legislating of science'.

Topics

Medical terms in this study, explained in our Lexicon: Asbestos Exposure, Permissible Exposure Limit (PEL), Time-Weighted Average (TWA), phase contrast microscopy (PCM), Transmission Electron Microscopy (TEM), Polarized Light Microscopy (PLM), Asbestos-Containing Material (ACM), OSHA.

Related studies

• An assessment of the Environmental Protection Agency's asbestos hazard evaluation algorithm — M.E. Findley, V.E. Rose, et al. (1983)
• EPA as a public health agency — B.D. Goldstein (1988)
• Counting rules for estimating concentrations of long asbestos fibers — K.S. Crump, D.W. Berman (2011)
• The WTC disaster and asbestos regulations — J.H. Lange (2004)
• Asbestos exposure of building maintenance personnel — S. Mlynarek, M. Corn, et al. (1996)
• Exposure science will not increase protection of workers from asbestos-caused diseases: NIOSH fails to provide needed public health action and leadership — R.A. Lemen, H. Anderson, et al. (2011)

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