Insight
FOR CONSULTANTS ; RISK ASSESSMENT
FOR CONSULTANTS
Watch Your Language
Warning: These Words Can Be Hazardous to Your Practice
BY DAVID KUDLINSKI
OSHA regulations serve as a main source of information and di-
rection for industrial hygiene practitioners. The regulations typi-
cally contain strong words of conviction, performance, extreme
measurement, and finite evaluation, such as “ensure,” “inspect,”
“all” and “required.”
Industrial hygiene practitioners are advised to be careful
when using these words and/or phrases in their own documenta-
tion because certain words, when used carelessly, may over-
promise results, mislead others, and misrepresent our intentions.
Would you, as the facility industrial hygiene manager, send
an e-mail to a plant manager that states, “I will inspect the press
room to ensure that all employees are safe”? As a consultant,
would you propose to a client, “Our technician will be on site at
all times to oversee the asbestos removal process to certify that
the project is completed satisfactorily”?
These examples contain words that are likely to be inappropriate for the circumstances. For more examples of troublesome
words and potential substitutes, see Table 1 on page 22.
I do not mean to imply that strong words and phrases should
never be used; nor do I condone vague and indefinite language
that could compromise an appropriate safety duty. Safety practices sometimes dictate the use of strong words, such as “Our
company’s policy is to provide training so that all employees
whose work is regulated by the OSHA Confined Spaces Standard
acquire the understanding, knowledge and skills necessary for
the safe performance of the confined space entry duties assigned.”
Words of Conviction
Industrial hygienists typically do not guarantee, certify, warrant,
ensure, insure or assure the safety of a particular work process
or condition. More likely, IHs assess, judge, estimate, infer, derive, believe or find meaning from a certain set of measurements
or observations.
For example, a personal exposure measurement of 10 parts
per million (ppm) of a substance is an estimate of exposure. It
indicates whether the employee was exposed above a particular
occupational exposure limit (OEL) during monitoring. Once IHs
have made a measurement, they can state that they find—but do
not guarantee—that the employee’s exposure exceeded (or did
not exceed) the OEL. Even if the gap between the measurements
and the OEL is wide, and the statistical confidence builds
through repeat measurements, IHs are advised to report the re-
