control banding for lead? You really
wouldn’t.” Control banding, Nelson says,
is most useful in situations where resources
are scarce and knowledge incomplete. For
example, small and medium-size employers who struggle to meet the requirements
of occupational health risk assessment—
collecting samples, having them analyzed,
and comparing the results to PELs—would
benefit from control banding, as would
developing nations that have few industrial hygiene professionals.
“In many developing countries, they
haven’t got an industrial hygiene labora-
tory. There isn’t a single MSA Model G
pump in the country,” Nelson says. “For
many chemicals there is no analytical
technique, there’s no standard. So we’re
forced to be creative and use some differ-
ent kinds of solutions to help protect
workers. And that’s what control banding
is all about: taking the information that
we have and using it in the best way to
provide good protection for workers.”
Is control banding poised to catch on
in the U.S.? Nelson and other supporters
acknowledge that much work remains to
be done, but she was heartened by the
reappointment of John Howard, a propo-
nent of control banding, as director of
NIOSH in September.
A PEL Groundswell?
Despite the changes evident throughout
government, updating PELs may not be
possible. Michaels, for example, has in-
dicated that OSHA resources would be
better spent elsewhere. In an article for the
winter 2009 issue of SafetyRep, the
newsletter of the New York Committee for
Occupational Safety and Health, Michaels
wrote, “OSHA is constrained by both
budget and legal authority. . . . The OSHA
standard setting process is broken and
OSHA lacks the resources or political clout
to issue an adequate set of new
standards.” 6
Ed Rutkowski is managing editor of The Synergist.
Hecanbereachedat(703)846-0734or
erutkowski@aiha.org.
References
1. Clayton, George D., and Florence
E. Clayton, eds.: The American
Industrial Hygiene Association: Its
History and Personalities, 1939–
1990. AIHA: Fairfax, VA (1994).
2. Skoglund, Robert, and Denese
Deeds: “Global Impact: GHS and
REACH Will Transform Worker
Safety and Health Programs.” The
Synergist, 20: 8 (2009).
3. Skoglund, Robert, and Denese
Deeds: “Global Impact: GHS and
REACH Will Transform Worker
Safety and Health Programs.” The
Synergist, 20: 8 (2009).
4. Zalk, David M., and Deborah Imel
Nelson: “History and Evolution
of Control Banding: A Review.”
J Occup Environ Hyg. 5( 5):330– 46
(2008).
5. NIOSH: Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding
(CB). [Online] Available at www.cdc.
gov/niosh/topics/ctrlbanding/ (2009).
6. Michaels, David: “Bold Campaign
Needed to Change Workplace
Culture.” SafetyRep, Winter 2009.