Unnecessary Workplace Chemical Exposures

Mary E. Greenhalgh is a Certified Industrial Hygienist. She is a Senior Industrial Hygienist with Counsel in Occupational Health, Inc. (COEH). Prior to this Ms. Greenhalgh was an OSHA Compliance Officer and was employed by an environmental health and safety (EHS) consulting firm.

Peter B. Harnett is a CIH. He founded COEH in 1992. Prior to this he worked for several EHS consulting firms and worked in biological research for MD Anderson Cancer Center.
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The recent New York Times article, “As OSHA Emphasizes Safety, Long-Term Health Risks Fester” accurately spotlights many shortcomings of the current system for dealing with workplace exposure to hazardous chemicals:

• It shows a flaw in the industrial hygiene philosophy of “substitution” of toxic chemicals for less toxic ones. In the highlighted example, n-propyl bromide (nPB) or 1-bromopropane was adopted as a presumably less toxic replacement for methylene chloride, known to cause acute health effects and currently considered by OSHA a potential occupational carcinogen. However, nPB is also known to cause serious health effects, including neurotoxicity and reproductive effects. In addition, NTP recently (2013) proposed listing it as “reasonably anticipated to be a human carcinogen.”
• It shows the effects of OSHA’s focus on the quicker safety inspections rather than the more time-consuming, labor-intensive health inspections that often involve months of investigation. OSHA is a relatively small agency with a small budget, and as long as OSHA and its inspectors are evaluated based on the number of inspections they complete, the preference for quick safety inspections will be difficult to change and chemical overexposures will continue to go uninvestigated.
• It highlights the effects of regulating one chemical at a time, and the effects of the lack of a coordinated interagency approach to regulating chemicals. The EPA’s emphasis on moving away from ozone depleting chemicals led to the shift from use of 1,1,1-trichloroethane (TCA) in glues used by the foam cushion industry to use of methylene chloride. This was followed by strict OSHA regulations that addressed methylene chloride, driving employers toward use of other chemicals, in this case nPB, unregulated by OSHA.

However, the article paid little attention to the most basic problem: overexposure of workers to a known toxic chemical when simple ventilation improvements and/or requiring use of appropriate respirators could provide improved protection. The solution to the problem is well-known but motivation to implement it is lacking. OSHA’s weak fines will not provide an incentive to implement controls that may be more costly than paying the fines for conducting business as usual.

Companies are better served by a strong OSHA. Many of the smaller companies do not have occupational health and industrial hygiene capability. Additionally a large portion of these small companies fail to adequately share chemical hazard information with their employees often because they do not understand the chemical hazard information and/or lack the expertise to communicate the hazards to employees. The result can include employees, who were unnecessarily harmed by avoidable chemical exposures and chemical manufacturers of the(se) chemical(s) often become defendants in toxic torts cases. The chemical manufacturers may provide adequate hazard communication on their chemical products, but these are not adequately communicated to employees.

The cost to our workers’ health and well-being and (avoidable) toxic torts litigation are not acceptable. By undertaking this compelling investigative story, the New York Times took a first step in the right direction in highlighting the issue of OSHA’s failure to address hazardous chemical exposure in the workplace.