explanation for this fact is that some
toxic effects associated with the substances
of interest were not known or not yet
proven with sufficient scientific evidence
at the time the OEL was set. Over time,
the generation of better scientific knowledge of these adverse effects has lead to
systematically lowered OELs. Given that
perhaps the largest portion of scientific
uncertainty resides in a basic lack of information, this heretofore historic trend
could be interpreted as a failure to handle
the uncertainty stemming from an admitted lack of basic knowledge. Given modern advances in toxicology, it is hoped
and anticipated that information about
the potential adverse effects associated
with chemical exposure will be anticipated and predicted more often and with
better accuracy. This, in turn, will allow
for a reasonable consideration of scientifically uncertain, but possible, adverse
outcomes and appropriately gauged OELs
that account for them. Such an approach
would imply an acceptance of the "pre-cautionary principle" for the occupational
environment.
Authors
The authors of this paper represent decades of experience in occupational health in
all sectors of the profession who are concerned enough about the lack of a more
global initiative in this arena that they agreed to set aside their affiliations and speak
to a broader advocacy:
Future Direction
We believe that industrial hygienists and
allied professionals consider 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.
The first step in this large task may
be to come to some agreement on a unitary scientific approach to assessing
hazards and applying hazard assessments to the setting of OELs. However,
many impediments exist to this seemingly obvious solution, including legal,
regulatory, economic, political and cultural issues and other factors outside of
the usual scientific arguments on health
effects. These difficulties have stalled
development of OELs in the U.S. and,
seemingly, the rest of the world. OELs
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 be developed.
Chuck Adkins, CIH, cadkins4@kc.rr.com
Lindsay Booher, CIH, lindsay.e.booher@exxonmobil.com
Dwight Culver, MD, MS, dculver@uci.edu
Tom Grumbles, CIH, tom.grumbles@us.sasol.com
Michel Guillemin, PhD, michel.guillemin@gmail.com
Frank Hearl, MS, PE, frank.hearl@cdc.hhs.gov
John Henshaw, CIH, john.henshaw@comcast.net
Michael A. Jayjock, PhD, CIH, mjayjock@gmail.com
Chris Laszcz-Davis, MS, CIH, REA, chrisld@EQ-Organization.com
Zack Mansdorf, PhD, CIH, CSP, QEP, mansdorf@tiac.net
Franklin E. Mirer, PhD, CIH, fmirer@hunter.cuny.edu
John Mulhausen, PhD, CIH, CSP
Frank M. Parker, III, CIH, CSP, PE, DEE, fparker3@calicheltd.com
Jimmy L. Perkins, PhD, CIH, perkinsjl@uthscsa.edu
Susan Ripple, MS, CIH, sdripple@gmail.com
Paul Schulte, PhD, paul.schulte@cdc.hhs.gov
Robert D. Soule, EdD, CIH, CSP, PE, bobsoule@auxmail.iup.edu
Litigation could further reduce, restrict
or eliminate the efforts of organizations
like ACGIH to generate new OELs. Many
in our profession consider this possibility
unacceptable. So, how can we revive the
OEL-setting process in a way that benefits all parties?
In Europe, REACH requires the development of DNELs. However, these values
will not be consensus recommendations—
they will be determined by the manufacturer or supplier of the material. Small
manufacturers will not have the resources
to do exhaustive studies, and the level of
scientific review of the DNELs, once submitted, is unclear. How effective this system will be in protecting workers remains
to be seen.
Control banding may be an alternative
approach to OELs. In theory, a well exe-
cuted process, guided by professionals who
appreciate the science of toxicology, can
set hazard bands for materials that lack ad-
equate toxicity and hazard data needed for
a formal OEL. However, the theory has not
been adequately tested to see if indeed the
process is protective. The specificity and
sensitivity of control banding has been only
minimally validated, and the preliminary
results have not been impressive.
