For Chris Laszcz-Davis, MS, CIH, REA,
any effort to change PELs must begin with
a broad education initiative and an acknowledgment that PELs are only one part
of a global concern in managing risk. This
conviction led her and an international
group of experienced OEHS leaders to set
aside their employer affiliations and coauthor a “green” paper titled “Occupational
Exposure Limits—Do They Have a Future?”
The paper, which is available on the website
of the International Occupational Hygiene
Association ( www.ioha.net/activities.html),
summarizes the evolution of occupational
exposure limits, describes contemporary
challenges facing occupational health and
safety professionals, and explores potential
remedies, including control banding.
“Our paper was an attempt to educate
folks so that they could move the dia-
logue forward,” Laszcz-Davis says. (Ex-
cerpts from the paper appear on pages
46–48.) “We agreed early on that proba-
bly one of the reasons there has been lit-
tle movement forward is that people
don’t understand the broader affiliated is-
sues, nor their potential impact. Many
don’t understand what’s gone on histori-
cally, nor do they understand that this is
not a domestic issue alone. It’s an inter-
national issue, particularly since so many
of our business sectors today operate
globally. Stakeholders from government,
industry, academia and labor may not be
fully aware of the range of options that
ought to be considered.”
Laszcz-Davis has witnessed firsthand
the relative importance of PELs—and envi-
ronmental health and safety regulations
in general—rise and fall over the years.
When she entered the industrial hygiene
profession in 1973, OSHA and EPA were
at the crest of a regulatory wave that .
had a galvanizing effect on industrial
hygiene and related professions. Increased
demand opened many doors for OEHS
professionals, and AIHA membership shot
up 400 percent between 1973 and 1983.1
Laszcz-Davis embarked on a career that
included executive-level industry, gov-
ernment and private consulting positions.
She now runs a private OEHS consulting
practice out of California, occasionally
lectures at the University of California-
Berkeley’s Center for Occupational and
Environmental Health and remains pro-
fessionally active internationally. For the
forthcoming edition of Patty’s Industrial
In May 2009, the AIHA Board of
Directors reiterated its commitment
to updating PELs. But the rapid
pace of change and uncertainty
about the priorities of OEHS
stakeholders require AIHA to be
open to different approaches.
Hygiene, Laszcz-Davis and several coauthors will contribute a chapter on risk
assessment that addresses the importance
of OELs.
“In the seventies, in this country par-
ticularly, government was the real driver
for the evolution of OEHS,” Laszcz-Davis
explains. “Many of us were very stan-
dards-compliance oriented because we
needed a common blueprint in this new
changing era. And then, as we moved
into the eighties and nineties, we began
to recognize that numbers and standards
conformance alone certainly didn’t guar-
antee that an organization would deliver
good OEHS processes and good outcomes.
We began to integrate management
processes, organizational leadership ini-
tiatives and systems safety processes with
the expectation that our OEHS processes
would ultimately make a difference. . . .
And so, there was less reliance on PELs
alone—they were always there, but when
you dealt with management—whether
staff or line—you certainly didn’t place a
PEL in front of them. While PELs were
necessary resources, they didn’t really
drive things as they did in the seventies.”
For Laszcz-Davis, the value of PELs
lies in the scientific information gather-
ing and collaboration used to arrive at a
commonly understood exposure limit for
a substance. Once everyone is in agree-
ment on the basic science, she says, the
limit generally takes care of itself.
“I don’t know that the final number is
as important as the process of scientists
getting together to arrive at a consistently understood, internationally set
database that provides us with the toxicology of different compounds and
chemicals that our workers use or that
our customers or the community are potentially exposed to,” Laszcz-Davis says.
“What seems to be missing is not so
much final numbers, although we certainly see a huge gap here, but making
sure we have the quality data, the research and the resources necessary so
people understand what the potential
toxic effects are for different end uses
and for full life cycles, how best to work
around them to mitigate risk, how to
make substitutions if possible, and what
to share with users so they can take the
appropriate precautions.”
Game Changer
REACH, possibly the most significant development in environmental and occupational health and safety regulations in
recent years, requires manufacturers of
chemicals intended to be introduced in
Europe to register with the European
Chemicals Agency. Manufacturers must
also present hazard and exposure data or
risk having their substances removed
from the market. For these reasons,
Laszcz-Davis and her colleagues describe
REACH as a “game changer.”
