For centuries the aphorism “All roads lead to Rome” has been used to convey the idea that there can be many different ways of reaching the same goal or conclusion. Likewise, in assessing potential risks to workers, consumers and the population at large to chemicals in commerce, there may be many different approaches used, but everyone is striving for a healthy environment for all Americans.
In the same spirit, the American Industrial Hygiene Association (AIHA) has partnered with the Foundation for Chemistry Research and Initiatives (FCRI), a 501(c)(3) tax-exempt organization established by the American Chemistry Council (ACC), to develop a workshop series bringing together thought-leaders from government, academia, industry, and organized labor to discuss occupational risk assessment under the theme of Many Paths, One Goal – Protecting Worker Health.
Many Paths, Many Approaches
The similarities and differences among occupational risk assessment approaches were the subject of a first workshop held in August of 2022 that focused on the various goals of risk assessments conducted at the National Institute for Occupational Safety and Health (NIOSH), the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA) and in conventional industrial hygiene practice. While the foundational underpinnings of risk assessment are common to all of these groups, there are differences based on the purpose for which such an assessment is undertaken.
NIOSH conducts risk assessments to support agency exposure control recommendations for workers; as part of the process for evaluating health hazards at work sites; as a component of epidemiological studies; or to assess the efficacy of engineering controls in particular industries.
OSHA conducts risk assessments to estimate how many workers are exposed within various exposure ranges for each industry sector. These estimates are used to mitigate potential illness or injury through risk management action under the OSHA regulatory program.
EPA conducts risk evaluations under the Toxic Substances Control Act (TSCA) to determine whether a chemical substance presents an unreasonable risk of injury to health under its conditions of use. Conditions of use include the manufacture, processing, distribution in commerce, use, or disposal of a chemical or a mixture/article containing the chemical. Workers are one potentially exposed subpopulation that is the subject of a risk evaluation.
Moreover, EPA’s risk evaluation covers a variety of industries and workers handling a particular chemical under differing scenarios across the country. In contrast, a typical industrial hygiene risk assessment is highly specific to a particular task at a particular location, with the objective of determining the needs for exposure control or mitigation. Both approaches are appropriate for their different purposes and decision contexts but can lead to different conclusions about risk that are important to understand and resolve to appropriately protect worker health.
The differing purposes of the risk assessments carried out by Federal agencies and occupational health professionals means that exposure assessment approaches will inevitably vary. Consequently, advantages and limitations of each approach for exposure assessment should be well understood so that data generated by each approach may be used and interpreted appropriately.
With respect to TSCA risk evaluations, participation by a broad array of stakeholders is valuable, including chemical manufacturers and importers, chemical users (i.e., product manufacturers), industrial and commercial workers, and other supporting professionals. Because standard practices do not always align between traditional industrial hygiene and general population risk assessments, occupational and environmental health and safety (OEHS) professionals and industrial hygienists play a key role in informing this process.
Improving Occupational Risk Evaluations
To that end, the AIHA-FCRI workshop series seeks to bring together these different parties to discuss approaches to occupational risk evaluation. These discussions can improve the inter-operability of data generated and enhance the occupational risk evaluations developed by EPA by:
- Clarifying the intended use of occupational exposure data through problem formulation and scoping.
- Developing procedures for utilizing available occupational exposure assessment data that may have been collected for different purposes.
- Developing updated methods for sampling and analysis in occupational monitoring.
- Updating input parameters used in exposure modeling to be current and representative.
- Developing risk assessment methods to account for the possibility of dermal exposure becoming an increasingly higher proportion of the total aggregate dose over time.
Workshop Series Objectives
Workshop topics are expected to cover:
- Identifying and using existing exposure data from various sources through application of analytics tools.
- Assessing and assuring the quality of the collection of occupational environmental safety and health data.
- Developing methods for evaluating occupational dermal exposure assessment where current approaches are less standardized than those for other exposure routes.
- Sharing insights on effective strategies for communicating risk and for disseminating risk management information.
One Goal: Protect Workers
The coming year looks to be extremely exciting and gratifying. The AIHA-FCRI partnership is one of several current multistakeholder activities that will foster dialogue and collaboration in advancing occupational exposure assessment, risk assessment and risk management. We hope it will be a productive route to a more healthful and safe work environment.
