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Occupational exposure limits - do they have a future?
Adkins-C; Booher-L; Culver-D; Grumbles-T; Guillemin-M; Hearl-F; Henshaw-J; Jaylock-MA; Laszcz-Davis-C; Mansdorf-Z; Mirer-FE; Mulhausen-J; Parker-FM III; Perkins-JL; Ripple-S; Schulte-P; Soule-RD
Derby, UK: International Occupational Hygiene Association, 2009 Aug; :1-12
We believe that Industrial Hygienists and allied professionals consider Occupational Exposure Limits (OELs) to be one of the most effective tools for performing risk assessments upon which risk management strategies for worker protection can be based. We may never have OELs for all chemical hazards; however, it is critical that we accelerate the establishment of credible and respected OELs to provide a basis for protecting workers. It could be argued that the first step in approaching this large task is to come to some agreement on a unitary scientific approach in assessing "hazard" and applying hazard assessments to OEL setting. This would allow more groups to become involved in a credible way. There are many roadblocks to this seemingly obvious solution. These include legal and regulatory issues, economic issues, political and cultural issues and other factors outside of the usual scientific arguments on health effects. These difficulties have resulted in an absence of any significant development of OELs in the United States and, seemingly, the rest of the world. Those that have been developed outside of the regulatory system as guidance have been subject to significant litigation. At our present rate of progress, it is extremely unlikely that significant numbers of new OELs will to be developed. Litigation could further reduce, restrict or eliminate the efforts of organizations like ACGIH to generate new OELs. There are many in our profession who consider this an unacceptable future. There are other potential approaches to this problem. So, how can we revive the OEL-setting process in a way that provides benefits to all parties involved? Europe has launched REACh which requires the development of DNELs. However, these will not be consensus recommendations, but rather values determined by the manufacturer or supplier of the material. These manufacturers and suppliers have a very broad range of technical resources and knowledge. As one might guess, small manufacturers will not have the resources to do exhaustive studies. The level of scientific review of the DNELs once submitted is unclear at this time. Additionally, it remains to be seen how effective this system will be in protecting workers. Control Banding is another approach some would suggest might take the place of OELs. Some would argue that Control Banding does incorporate the concept of OELs since they are defined in hazard bands or ranges of target exposure rather than single values. They certainly move the user towards a decision of "how much is too much." The big advantage is that, if well executed and guided by professionals who appreciate the science of toxicology, hazard bands can be set for materials that may not have enough toxicity and hazard data available to set a formal single point OEL. Nevertheless, Control Banding still ultimately requires some form of OEL to be adequately applied. Furthermore, the specificity and sensitivity of Control Banding has only been minimally validated, and the preliminary results have not been impressive. There are governments around the world that are still establishing OELs. These values are not generally applied outside of the host country and may include many more considerations than just health effects in their derivation. Additionally, actual measurements for ambient air levels of the OEL substances are rarely performed except in a few countries. This suggests that the traditional use of OELs is not widely practiced worldwide. In closing, we believe that Occupational Exposure Limits (OELs) are absolutely critical. We hope that this Paper will encourage our broad audience of stakeholders to discuss the critical issues, continue the dialogue and, as a call to action, help determine what the future for OELs should be. In working together, our profession can lead a way forward! The authors and contributors welcome your thoughts and input. The challenges and opportunities described impact us all. We believe they are significant enough that action needs to be taken sooner rather than later. Please send us your comments and thoughts on this issue and the options available to approach this challenge. Your input will help us determine how to move forward.
Standards; Regulations; Risk-analysis; Occupational Exposure Limits; OELs; Risk assessment; Risk management; Chemical hazards; Control banding; Hazard banding
Occupational Exposure Limits - Do they have a Future?