to a finite checklist of applicable OSHA
regulations.
In regard to air monitoring, IHs usually compare results to occupational exposure limits (OELs) or other air quality
standards. But just because the results of
representative air monitoring of an area
or person are within OELs or other standards does not mean that IHs should describe an area as “safe.” For example,
when the visual-cleanliness inspection
and air sampling of an area after asbestos removal meets the EPA guidance
criteria in a commercial building, the asbestos contractor is typically released
and the area may be reoccupied by unprotected personnel. But the area may
not be safe for further activities, such as
demolition or renovation, if additional
hazards remain. Therefore, the area
would not be necessarily safe.
The Psychology of Words
IHs who overuse finite words of evalua-
tion may appear to be authoritarian and
unreceptive to criticism. For example:
“The test result of the batch mixer’s
exposure is twelve times the OEL for the
powder. It is critical that the mixer wears
a full-face respirator. This is the required
respirator approved by the IH Depart-
ment, and it is necessary for the batch
mixing process. It is not satisfactory for
the mixer to use a half-face respirator as
he does now.”
These statements communicate that a
finite evaluation has already been made.
The IH does not appear open to enter-
taining administrative and engineering
controls for the mixing process, suggest-
ing a review for potential anomalies dur-
ing the exposure test, considering more
testing, or inviting input by the mixing
department.
nance supervisor, and it is good news.
He is confident about working on energized wiring while the conveyor belt
continues to run. I believe he can do the
job with low risk. Along those lines, it is
recommended that our company formally evaluate the safety issues with
electrical procedures around the plant in
the near future to comply with OSHA.”
Watch Your Language
Laws and regulations typically contain
strong words of conviction, performance,
extreme measurement, and finite evaluation. When IHs prepare their own documentation, these words can be used
when appropriate—but they should be
used carefully.
David N. Kudlinski, CIH, CSP, is a consultant with
BureauVeritas.Hecanbereachedat(714)431-
4125ordavid.kudlinski@us.bureauveritas.com.
Check out the newest publication to hit the shelves of AIHA
The Radiation Safety Officer Survival Handbook
By Joseph Vincelli, Norman W. Henry III, John Miller, James R. Weldy
Stock# ERDH09-760 Member Price: $55 Nonmember Price: $69
The use of radiation in research, medicine, and industry is highly regulated. Safety profes-
sionals working with radiation must possess not only a good understanding of science but
also of regulatory requirements. The RSO Handbook provides an introduction to radiation
safety, including basic radiation science, radiation safety practices and procedures, and
federal or state regulations. References and examples of forms to be used for surveys, audits,
or other specific investigations. The information provided in this reference will benefit the
RSO working in an academic, research or medical facility.
AIHA Publications—Reliable References for OEHS Professionals Globally
Check out this book and all others
at www.aiha.org/market.
™
Call AIHA Customer Service at (703) 849-8888 for more information.