Cautionary Tales in Lab Safety - Extended Edition

The Industrious Hygienist has just posted the extended edition of "Cautionary Tales in Lab Safety," our #IHFundance third place winning video from AIHce 2015! 




We hope you enjoy the extended edition, which includes roughly 22 seconds of content we had to cut or shorten from the original video to meet the 2 minute time limit for #IHFundance.

We're working on more videos for 2016, including a short spill response training video, a video about Chemical Hygiene Plans for laboratories, and another general laboratory safety video. Thanks for watching and sharing Sock Puppet Safety!

What's an Exposome? Recent Research on Occupational Exposure Limits

The Journal of Occupational and Environmental Hygiene (JOEH) is the official publication of the American Industrial Hygiene Association (AIHA) and the American Conference of Governmental Industrial Hygienists (ACGIH). JOEH released a supplemental journal issue for 2015 entitled: �Special Issue: State of the Science of Occupational Exposure Limit Methods and Guidance.� 

This supplemental issue contains nine research articles and two introductory/summary articles detailing recent research in occupational exposure limits (OELs). Members of AIHA and/or ACGIH can log in to their respective member portals to view the research articles referenced below. This blog post is a high-level summary of each of the articles, including best practices that can be used by practicing industrial hygiene and safety professionals.

The Past and Future of Occupational Exposure Limits

This introductory article by Jonathan Borak and Lisa M. Brosseau about �The Past and Future of Occupational Exposure Limits� is a quick history of OELs and analysis of the barriers present in developing new OELs. The authors note that the ten articles �present a systematic approach that begins with an understanding of systems biology, mechanisms of action and the early (i.e., �pre-clinical�) effects of toxic exposures including genetic and epigenetic phenomena.� 

The most obvious barrier to developing OELs is the lack of data available that is relevant to human occupational exposure. Another barrier is the difficulty in establishing global exposure limits � since countries are at different stages of industrialization and the necessary controls may be infeasible. The third barrier mentioned by the authors is the lack of a formal, systematic approach to develop, establish, and update OELs.

Occupational Exposure Limit Derivation and Application

In a summary article titled �State-of-the-Science: The Evolution of Occupational Exposure Limit Derivation and Application� authors A. Maier, T. J. Lentz, K. L. MacMahon, L. T. McKernan, C. Whittaker, and  P. A. Schulte provide a review of the research articles provided in the JOEH supplement. The four-page summary article explains that the research articles in the JOEH supplement are not an exhaustive assessment of OELs, but they explain scientific advances to be considered for risk assessment and management of occupational hazards.

Historical Context for OELs

The first research article in this JOEH supplement is �Historical Context and Recent Advances in Exposure-Response Estimation for Deriving Occupational Exposure Limits� by M.W. Wheeler, R. M. Park, A. J. Bailer, and C. Whittaker. In the abstract of the article, the authors explain that most occupational exposure limits are not based on quantitative risk assessment (QRA), and provide examples of exposure-response modeling methods available for QRA. �The key step in QRA is estimation of the exposure-response relationship,� the authors state, recommending the use of statistical tools to properly characterize the risk.

One of the best takeaways of the article is found in Table 1: �Common Impediments to Inference When Developing an Exposure-Response Relationship from Epidemiological Studies.� This table presents issues such as confounding bias, selection bias, the healthy worker effect, reverse causation, and variable susceptibility, and provides the consequences and fixes for these issues when working on exposure-response relationships. Table 1 is a helpful summary for industrial hygienists or safety professionals who are just starting their education into epidemiology.

Another helpful element of the article is found in Table 7: �OEL Estimation Methods,� which sets forth the data requirements, considerations for use, epidemiological considerations, and caveats for estimation methods such as the no observed adverse effect level (NOAEL), traditional benchmark dose (BMD), and biologically-based methods. In the conclusion of the article, the authors recommend that risk managers select the proper �statistical methodology to estimate risks and quantify relevant uncertainties� in occupational risks.

Dosimetry Modeling for Occupational Risk Assessment

An article by Eileen D. Kuempel, Lisa M. Sweeney, John B. Morris, and Annie M. Jarabek explains the �Advances in Inhalation Dosimetry Models and Methods for Occupational Risk Assessment and Exposure Limit Derivation.� This article introduces the basic concepts of dosimetry, explains the hierarchical model selection criteria, considers agent-specific dosimetry and model selection with agent-specific examples, and discusses challenges to implementing dosimetry models and methods in risk assessment and OEL derivation.

When introducing the basic concepts of dosimetry, the authors explain that dosimetry involves determining the amount, rate, and distribution of a substance in the body. They also introduce the development and use of risk-based exposure estimates including the NOAEL, the lowest observed adverse effect level (LOAEL), and the benchmark dose (BMD), which is �the dose associated with a specified risk (e.g., 10%) of an adverse health effect (or benchmark response) as estimated from modeling the dose-response relationship.�

The authors explain that dosimetry is essential for understanding the relationship between exposure and the body�s response. Dosimetry can improve the accuracy of risk assessment by reducing the level of uncertainty in the calculated estimates. Reliable estimates of the internal dose at the target organ or tissue are accomplished by specific measurements or predictive models. 

The article focuses on inhalation dosimetry since it is a significant route of occupational exposure. Detailed mechanisms and models are provided for the respiratory tract, deposition of particles of fibers, clearance and retention of inhaled particles and fibers (including an interspecies comparison), and gas uptake factors. The interspecies comparisons discuss that similar clearance pathways are used by both humans and laboratory animals, but that extrapolation of animal data for human exposure estimates has changed due to an improved understanding of the differences between animal and human respiration.

Using Systems Biology and Biomarkers

The third research article in this JOEH supplement presents the use of �Systems Biology and Biomarkers of Early Effects for Occupational Exposure Limit Setting� as written by D. Gayle DeBord, Lyle Burgoon, Stephen W. Edwards, Lynne T. Haber, M. Helen Kanitz, Eileen Kuempel, Russell S. Thomas, and Berran Yucesoy. As provided in the abstract of the article, this article discusses �systems biology, biomarkers of effect, and computational toxicology approaches and their relevance to the occupational exposure limit setting process.� In the introduction, the authors mention the dearth of toxicity information known at present about tens of thousands of chemicals in use in industry today.

The authors note that complex exposure scenarios, where workers are �exposed to complex mixtures that may have additive, synergistic, or antagonistic actions� makes it difficult to conduct thorough risk assessments. Useful portions of this article include Table 1: �Glossary of Key Terms.� Table 1 provides definitions for key terms used in the article, including: benchmark dose (BMD), benchmark response (BMR), biomarkers, computational toxicology, metabolomics, proteomics, systems biology, and uncertainty factors.

A biomarker is an �[i]nternal [measure] or [marker] of exposures or effects for a chemical or agent in the body.� Research into biomarkers involves an assessment of which biomarkers can be quantitatively linked to human adverse outcomes from occupational exposure. The authors explain that �[e]nvironmental exposures can directly or indirectly cause alterations in gene expression at either the transcriptional (gene expression) or the translational level (proteomics).� Table 4: �Different Types of Biomarkers� shows the type of biomarker (exposure, effect, or susceptibility), its characteristics, and examples.

In the conclusion, the authors explain the advantages of using biomarkers, since they can be used to �establish more appropriate OELs to protect individuals who are at high risk.� They caution that the �whole field of computational toxicology and systems biology is still evolving and results have not been validated in human populations� and that interpretation of biomarker results is not yet available. These challenges need to be overcome before biomarkers can be used routinely in human occupational risk assessment.

Scientific Basis of Uncertainty Factors

An article by D. A. Dankovic, B. D. Naumann, A. Maier, M. L. Dourson, and L. S. Levy discusses �The Scientific Basis of Uncertainty Factors Used in Setting Occupational Exposure Limits.� The abstract of the research article explains that �[t]he use of uncertainty factors is predicated on the assumption that a sufficient reduction in exposure from those at the boundary for the onset of adverse effects will yield a safe exposure level for at least the great majority of the exposed population, including vulnerable subgroups.�

Of interest to practicing industrial hygienists and safety professionals, Table 1: �UFs Used in OEL-setting, and the Rationale for Their Use� explains the types of uncertainty factors, which area of uncertainty they are used for, and the basic principles when rationalizing their use in risk assessment and OEL setting. For example, UF_A is used for animal to human uncertainty, and is used to adjust for differences in sensitivity between animals and the average human (not the occupationally exposed human). Figure 5 shows the hierarchy of approaches that are available when incorporating chemical exposure data into the risk assessment process, in order to improve scientific certainty.

Using Genetic and Epigenetic Information

The fifth article in the JOEH supplement by P. A. Schulte, C. Whittaker, and C. P. Curra is an introductory evaluation of �Considerations for Using Genetic and Epigenetic Information in Occupational Health Risk Assessment and Standard Setting.� The authors note that genetic and epigenetic data have not been widely used in risk assessment for occupational health. However, the authors envision that �genetic and epigenetic data might be used as endpoints in hazard identification, as indicators of exposure, as effect modifiers in exposure assessment and dose-response modeling, as descriptors of mode of action, and to characterize toxicity pathways.�

When evaluating the use of epigenetics in occupational health, the authors mention that using �epigenetics in epidemiologic studies of occupational disease may help explain the relationship between the genome and the work environment; however, other environmental exposures outside of work� also will need to be controlled for. Practicing industrial hygiene and safety professionals may be interested in Table 1: �Guide to Assessing Genetic and Epigenetic Data for Risk Assessment,� which is a 4 � 4 matrix showing the types of risk assessment functions (hazard identification, dose-response modeling, exposure assessment, and risk characterization) and the questions associated with using genetic or epigenetic data (both inherited and acquired) that may be asked.

Table 2: �Framework for use of genetic and epigenetic data in occupational and environmental risk assessment� is also interesting, since it uses the same 4 x 4 matrix and risk assessment functions with the recommended or estimated use of genetic and epigenetic data. For example, for the exposure assessment function, acquired genetic data can show deviations from normal pattern of gene expression, whereas inherited epigenetic data can be used as an indicator of exposure.

In the conclusion, the authors state that: �It is not far-fetched that a worker�s �Right to Know� might someday extend to the worker�s right to know their genetic susceptibility to workplace toxicants.� This is an intriguing idea for future research.

Setting OELs for Chemical Allergens

In an interesting article about �Setting Occupational Exposure Limits for Chemical Allergens�Understanding the Challenges� by G. S. Dotson, A. Maier, P. D. Siegel, S. E. Anderson, B. J. Green, A. B. Stefaniak, C. D. Codispoti, and I. Kimber, the authors discuss establishing exposure limits for low molecular weight (LMW) chemical allergens. The definition of chemical allergy is explained as �immune-mediated adverse health effects, including allergic sensitization and diseases, caused by exposures to chemicals.�

LMW allergens that are recognized occupational hazards include: diisocyanates, organic anhydrides (i.e., maleic anhydride) and some metals (i.e., beryllium and nickel). Table 1: �ACGIH Threshold Limit Values (TLVs) Based on Immune-mediated Health Endpoints� provides a list of chemical allergens with OELs already developed. These chemical allergens include beryllium, flour dust, natural rubber latex, various diisocyanates, and piperazine.

The article also provides an explanation of the biology of chemical allergens, including the difference between sensitization and elicitation, and forms of chemical allergy. The authors note that the two forms of chemical allergy of most interest to occupational health professionals are skin sensitization (resulting in allergic eczema and contact dermatitis) and respiratory tract sensitization (resulting in asthma and rhinitis). Specific challenges associated with development of OELs for chemical allergens are also discussed.

Exposure Estimation and Interpretation of Occupational Risk

The seventh article in the JOEH supplement provides a detailed analysis of �Exposure Estimation and Interpretation of Occupational Risk: Enhanced Information for the Occupational Risk Manager� by Martha Waters, Lauralynn McKernan, Andrew Maier, Michael Jayjock, Val Schaeffer, and Lisa Brosseau. The authors explain the risk characterization process for occupational exposures, including the regulatory basis for OELs, describing exposures and the exposed population(s), intrinsic variability and how to reduce uncertainty in exposure estimation, and methods for estimating exposures.

Table 1: �Occupational Exposure Limits (OELs) Developed by Various Organizations� shows the various OELs, which organization has set them, and whether they were developed based on a health basis, analytical feasibility, economic feasibility, and engineering feasibility. The authors provide an example of the compliance approaches used by the Occupational Safety and Health Administration (OSHA) and National Institute for Occupational Safety and Health (NIOSH). OSHA and NIOSH�s �[approach] include[s] collecting samples from the worst case exposure scenario or randomly from a defined similar exposure group of interest. The measurement is compared to the OEL and is classified into one of three decision categories: clearly below the limit, clearly above the limit, or too close to the limit for an immediate decision.�

The authors also provide an explanation of the AIHA exposure assessment strategy, which �recommended that [time-weighted average (TWA)] OELs be interpreted as upper limits of exposure (e.g., 95th percentile) for each similar exposure group (SEG) and that the exposure distribution profile of each SEG should be controlled so that the 95th percentile exposure is less than the OEL over time.� Following the discussion of SEGs, a short section on Bayesian methods is provided.

Aggregate Exposure and Cumulative Risk Assessment

In this research article about �Aggregate Exposure and Cumulative Risk Assessment�Integrating Occupational and Non-occupational Risk Factors,� T. J. Lentz, G. S. Dotson, P. R.D. Williams, A. Maier, B. Gadagbui, S. P. Pandalai, A. Lamba, F. Hearl, and M. Mumtaz evaluate the benefits of considering non-occupational exposures as part of the occupational risk assessment. The authors debate using a �combined risk from exposure to both chemical and non-chemical stressors, within and beyond the workplace,� with the understanding that �such exposures may cause interactions or modify the toxic effects observed (cumulative risk).�

Like previous articles in this OEL series, the authors provide a glossary of key terms in Table 1, including aggregate risk, exposome, and total worker health. Exposome is defined as �the measure of all the exposures of an individual in a lifetime and how those exposures relate to health.� Exposomics is defined as �the study of the exposome, which relies on the application of internal and external exposure assessment methods.�

Figure 2 of this article will be of special interest to practicing industrial hygienists and safety professionals. It is an illustration of the relationship between the key factors that must be considered in a cumulative risk assessment. The primary factors are divided into three categories: occupational factors, non-occupational factors, and individual factors. The occupational and non-occupational factors are further divided into settings, sources, pathways, dominant exposure routes, key stressors, and effects. Using the illustration in Figure 2, the authors provide an illustrative case study in Figure 3 to assess the cumulative risk for hearing loss.

The Global Landscape of OELs

In this ninth and final research article from the JOEH supplement, �The Global Landscape of Occupational Exposure Limits�Implementation of Harmonization Principles to Guide Limit Selection� is discussed by M. Deveau, C-P Chen, G. Johanson, D. Krewski, A. Maier, K. J. Niven, S. Ripple, P. A. Schulte, J. Silk, J. H. Urbanus, D. M. Zalk, and R. W. Niemeier. The article�s abstract notes that an occupational hygienist seeking to determine the proper OEL to apply in an international setting will encounter a �confusing international landscape for identifying and applying such limits in workplaces.�

Practicing industrial hygienists and safety professionals may be interested in Figure 1, which is a reprint of the hierarchy of risk-based occupational exposure benchmarks as developed by AIHA in their publications on control banding and SEGs. The authors note that the goal of international harmonization for OEL derivation and development has been under much debate and discussion, and explains the existing harmonization initiatives in place.

Conclusion

As occupational health and safety professionals, industrial hygienists can have access to new and exciting research by academic, governmental, and other groups through journals such as JOEH. In their supplemental issue about OELs, JOEH has selected nine research articles that provide the current state of occupational exposure science. This blog post has summarized the contents of each article and provided takeaways and interesting quotes from the articles, to allow practicing industrial hygiene and safety professionals to focus their continuing safety education on the articles that will most interest them.

#IHFundance - Cautionary Tales in Lab Safety!

Greetings, loyal readers!

Please take 2 minutes out of your very busy day and check out "Cautionary Tales in Lab Safety," our first ever Sock Puppet Safety video on YouTube. This is a video submission for the IH Fundance Film Festival Contest at AIHce 2015 in Salt Lake City, UT.

The Industrious Hygienist will not be able to attend AIHce this year, but if you are going to the conference, please vote for my video! I promise to make more fun videos if we win. 

However, the Industrious Hygienist will be attending Safety 2015 in Dallas, TX in June. I hope to meet up with fellow safety and industrial hygiene nerds - I might even bring a puppet with me. If you're at Safety 2015, please also contribute to my roundtable at Session #625, "Safety Implications of Chemical Disinfectants in Healthcare." 

The roundtable is intended to discuss the following: "Healthcare associated infections represent a significant challenge to patient safety. To control this emerging threat, new chemicals and novel applications of existing chemicals are being marketed heavily to the healthcare industry. This roundtable will discuss challenges and attempt to build consensus on development of a proactive Health & Safety assessment model which balances staff and patient safety."

Wish us luck in the IH Fundance Film Festival! Vote for my puppets!

Leave us comments on YouTube if there are specific safety and industrial hygiene topics you'd like to see acted by our cadre of puppets. 

DIY Safety Data Sheet Revision in Three Easy Steps

Manufacturers and importers of hazardous chemicals have until June 1, 2015 to update their labels and material safety data sheets to be in compliance with the Hazard Communication Standard (HCS) final rule promulgated by the Occupational Safety and Health Administration (OSHA). While you�re patiently waiting for manufacturers to conduct the revisions to labels and updating material safety data sheets to reflect the 16-section format required for Safety Data Sheets (SDS), you still have to train your employees in the new label elements and new SDS format.

OSHA has put together Quick Cards for sample labels and SDS, explaining the new requirements, but some employees and safety professionals may find it difficult to train employees without real, concrete examples. Many manufacturers and importers may also be moving slowly on their revisions due to the perceived difficulty of completing the revisions.

To assist safety professionals and industrial hygienists in their training, here�s some do-it-yourself (DIY) 3-step guidance on preparing your own labels and SDS.

Step 1: Review the requirements for SDS and labels.

First look at the OSHA sample label and list of the 16 required sections for an SDS. If you haven�t looked at your HCP lately, it�s also a good time to revise and update your program. OSHA provides guidance on establishing and maintaining your HCP in their �Small Entity Compliance Guide for Employers That Use Hazardous Chemicals.� 

Next, it might be helpful to review Annex 4 of theGlobally Harmonized System for the Classification and Labelling of Chemicals(GHS), Third Revised Edition (2009). Annex 4 is entitled �Guidance on the Preparation of Safety Data Sheets (SDS)� and explains the purpose of each of the 16 sections in detail. 

Please note that OSHA cannot enforce the content of Sections 12 to 15 of the SDS, as these sections are enforced by other regulatory agencies like the U.S. Environmental Protection Agency (EPA) and U.S. Department of Transportation (DOT) that have not yet adopted GHS.

Step 2: Figure out the hazard classification and category of the substance or mixture.

This is the hardest part of SDS and label preparation � figuring out how to properly classify the substance or mixture. If you want to read through GHS Part 2: Physical Hazards and Part 3: Health Hazards to get an idea of the complexity of this task, you can, but you may find it overwhelming.

You�ll need some knowledge of toxicology and management of hazardous materials to complete this task. If you�re lucky, you�ll find a SDS already prepared by another manufacturer (usually with international capability who already has GHS-compliant SDS) that contains the hazard classification of the substance or mixture.

You have to assess if your chemical constitutes a physical hazard, a health hazard, or both. Some examples of physical and health hazards are included below.

Physical Hazard

Explosives
Flammable Gases
Flammable Aerosols
Gases Under Pressure
Flammable Liquids
Self-Reactive Substances and Mixtures
Pyrophoric Solids
Oxidizing Liquids
Organic Peroxides
Corrosive to Metals

Health Hazard

Acute Toxicity
Skin Corrosion/Irritation
Serious Eye Damage/Eye Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Specific Target Organ Toxicity � Single Exposure
Specific Target Organ Toxicity � Repeated Exposure
Aspiration Hazard

Physical Hazard: Here�s where the hazardous materials management knowledge will come in handy. You�ll want to find the upper and lower flammable limit/range of your chemical or mixture at standard pressure; understand whether you have a compressed gas, liquefied gas, refrigerated liquefied gas, or dissolved gas; know the flash point for your chemical or mixture; research the burning rate of your flammable solid; research the heat of decomposition; and know the corrosion rate or steel and/or aluminum.

Health Hazard: This is where knowledge of toxicology and ability to search various institutional databases will be useful.

Acute Toxicity:look up the various lethal doses for each anticipated exposure route (oral, inhalation, dermal, etc.). The LD50 indicates the lethal dose in 50% of test subjects (oral, dermal, and other routes) and the LC50 indicates the lethal concentration in 50% of test subjects (inhalation route).

Useful sources for health hazards:

• National Institutes of Health ToxNet � Hazardous Substances Data Bank (HSDB): Look up the chemical(s) by Chemical Abstract Service (CAS) number or chemical name. This provides information on human health effects, emergency medical treatment, animal toxicity studies, environmental fate, chemical/physical properties, chemical safety and handling, and occupational exposure standards.
• Centers for Disease Control and Prevention (CDC), National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards: Look up the chemical(s) by CAS number of chemical name. This provides the synonyms and trade names, conversion rates, DOT Emergency Response Guide number, Immediately Dangerous to Life and Health (ILDH) concentration, recommended measurement methods, exposure limits, physical description, exposure routes, symptoms, incompatibilities and reactivities, personal protection, and first aid recommendations.
• Registry of Toxic Effects of Chemical Substances (RTECS), linked from NIOSH Pocket Guide to Chemical Hazards: This provides skin and eye irritation data, mutation data, reproductive effects, and acute toxicity data. 
• OSHA Occupational Chemical Database: This compiles information from the DOT Emergency Response Guidebook, NIOSH Pocket Guide to Chemical Hazards, and OSHA Chemical Sampling Information webpage.
• Agency for Toxic Substances and Disease Registry (ATSDR) Toxic Substances Portal: Provides toxicological profiles, public health concerns, and health effects; search by CAS number of chemical name.
• ATSDR Medical Management Guidelines: Use for basic chemical and exposure information, a summary of potential health effects (acute and chronic), routes of exposure, and incompatibilities.

Step 3: Start Writing the SDS.

Once you have the hazard classification for each chemical or mixture, the rest of the SDS is mostly data gathering.

Section 1 � Identification

Include the product identifier (as used on the label), other means of identification, recommended use, supplier�s details, and emergency phone number.

Section 2 � Hazard Identification

Using the hazard classification, go to Annex 3 for the �Codification of Hazard Statements, Codification and Use of Precautionary Statements and Examples of Precautionary Pictograms.� Look through the listed Hazard Statement codes for physical hazards in Table A3.1.1 and it will tell you what hazard statements and pictograms belong on the SDS and label based on the hazard class. There are also tables for the various Precautionary Statements (prevention, response, storage and disposal). Or, to make it simpler, on page 336 of Annex 3, there is a series of tables encompassing much of the rest of the Annex showing the required signal word, hazard statement, symbol, and precautionary statement(s) based on the hazard classification and associated hazard category. It makes Section 2 very simple to accomplish.

Pictograms can be downloaded as .JPG files from OSHA here.

Health Hazard Pictogram

Section 3 � Composition/Information on Ingredients

This should be present on the original material safety data sheet you are converting to SDS format.

Section 4 � First Aid Measures

This information can be obtained from the NIOSH Pocket Guide to Chemical Hazards, DOT Emergency Response Guidebook, ATSDR Medical Management Guidelines, or ToxNet HSDB. Provide first aid measures for each anticipated route of entry (eye contact, skin contact, inhalation or breathing, ingestion or swallowed).

For information about the most important symptoms (acute and delayed), and indication of immediate medical attention and special treatment needed, the sources listed above for researching health hazards will be useful.

Section 5 � Fire-Fighting Measures

Information from this section can be easily obtained from the NIOSH Pocket Guide to Chemical Hazards and DOT Emergency Response Guidebook, by finding the Guide number that matches the chemical(s) on your SDS and reviewing the emergency response fire information. Make sure to include the ILDH concentration from the NIOSH Pocket Guide to Chemical Hazards, as applicable.

Section 6 � Accidental Release Measures

Information from this section can be easily obtained from the DOT Emergency Response Guidebook, by finding the Guide number that matches the chemical(s) on your SDS and reviewing the emergency response spill or leak information.

Section 7 � Handling and Storage

The precautions for safe handling and conditions for safe storage, including any incompatibilities, is retrievable from the OSHA Occupational Chemical Database, ToxNet HSDB, and NIOSH Pocket Guide to Chemical Hazards. Make sure to include information on whether a safety eye wash and/or shower is required when using this chemical.

Section 8 � Exposure Controls/Personal Protection

Include relevant exposure limits here. It is best practice to include the following for each chemical, as applicable:

• OSHA Permissible Exposure Limit (PEL)
• NIOSH Recommended Exposure Limit (REL) � found in NIOSH Pocket Guide to Chemical Hazards
• American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV)

This section should also include information if the chemical(s) is a carcinogen, and include engineering controls and personal protective equipment (PPE) for the anticipated routes of entry (eye/face protection, skin protection, respiratory protection).

Useful resources for determining the proper PPE are included below:

• Quick Selection Guide to Chemical Protective Clothing (2014, 6^th Edition)
• OSHA Technical Manual � Chemical Protective Clothing
• Canadian Centre for Occupational Health and Safety � Chemical Protective Clothing
  

Section 9 � Physical and Chemical Properties

This should be present on the original material safety data sheet you are converting to SDS format. Alternatively, the information on each chemical(s) may be able to be obtained from the ToxNet HSDB and the International Chemical Safety Cards by the CDC. The International Chemical Safety Cards can be searched by CAS number, chemical name, RTECS number, and UN number.

Section 10 � Stability and Reactivity

Your research using the ToxNet HSDB, OSHA Occupational Chemical Database, and NIOSH Pocket Guide to Chemical Hazards will have identified the stability and reactivity of the chemical(s) you are researching.

Section 11 � Toxicological Information

Your research using the ToxNet HSDB and ATSDR Toxic Substances Portalwill have given you much of this information. Make sure to verify the carcinogenicity from ACGIH, International Agency for Research on Cancer (IARC), EPA Integrated Risk Information System, National Toxicology Program (NTP), and OSHA.

Section 12 � Ecological Information, Section 13 � Disposal Consideration, Section 14 � Transport Information, and Section 15 � Regulatory Information

These sections are not required by OSHA at this time; you can include the information or state �This section is not required according to 29 CFR 1910.1200(g)(2)� if your SDS is being developed for internal use only.

Section 16 � Other Information

This section can include the date of preparation of the last revision of the SDS, literature references and sources for data used to compile information for the SDS, a key for abbreviations, National Fire Protection Association (NFPA) and Hazardous Materials Information System (HMIS) ratings, and any internal �safety notices� or legalese you�re required to place at the end of every SDS by your corporate counsel.

Completion and Review

Request that a colleague review the SDS for typos and accuracy. Make sure the hazard statements and precautionary statements are correct for the hazard classification and associated category you have selected for the chemical(s) on the SDS. Double check CAS numbers and chemical concentrations.

Once the SDS revision is complete, if you have a need for facility-specific labels, this is a simple process. All the information you need for the label can be copy/pasted from the SDS to the label. The pictograms can be downloaded from OSHA�s Hazard Communication website for use in container labels. You�ll be surprised how much you�ll learn when completing the SDS revision.

Happy Father's Day! And a new manga.

In honor of Father's Day, I drew this for my father. He's the guy everyone calls when they have a question about computers, or cars, or electrical issues, or pretty much anything...it makes my mother crazy sometimes, but she appreciates his efforts to serve others.

My freshman year in college, I was in multiple car accidents, all minor, one partially my fault. He kept my 1990 Honda Civic (affectionately named Sterling) running from my senior year of high school until I was able to sell it and buy my first new-ish car after I got my first real job out of college.

I learned most of my computer troubleshooting skills from him as well. 

A few years ago, he had a scary encounter with off-the-job chemical exposure that I have memorialized here. 

Thanks for everything you do for me, Dad!

Happy Father's Day from the Industrious Hygienist!

Need help with (insert topic here)? There's an ASTM Standard for that!

I have been slowly purchasing and collecting ASTM International Standards for years (they're not entirely cheap), and this weekend, I developed a wish list of ASTM standards I plan to purchase in 2014.

Under Industrial Hygiene and Safety Standards:

ASTM E2238 - 12: Standard Guide for Evacuation Route Diagrams ($37)

ASTM F1461 - 12: Standard Practice for Chemical Protective Clothing Program ($42)

ASTM D4276 - 02 (2012): Standard Practice for Confined Area Entry ($37)

ASTM E2565 - 09: Standard Guide for Consensus-based Process for an Occupational Safety and Health Standard that Includes an Occupational Exposure Guideline ($37)

For Asbestos:

ASTM E2356 - 10: Standard Practice for Comprehensive Building Asbestos Surveys ($67)

ASTM E1368 - 11: Standard Practice for Visual Inspection of Asbestos Abatement Projects ($48)

ASTM D7201 - 06 (2011): Standard Practice for Sampling and Counting Airborne Fibers, Including Asbestos Fibers, in the Workplace, by Phase Contrast Microscopy (with an Option of Transmission Electron Microscopy) ($60)

For Lead:

ASTM E2255 / E2255M - 13: Standard Practice for Conducting Visual Assessments for Lead Hazards in Buildings ($48)

ASTM E2239 - 12: Standard Practice for Record Keeping and Record Preservation for Lead Hazard Activities ($37)

For Mold and Indoor Air Quality (IAQ):

ASTM D7338 - 10: Standard Guide for Assessment Of Fungal Growth in Buildings ($42)

ASTM D6245 - 12: Standard Guide for Using Indoor Carbon Dioxide Concentrations to Evaluate Indoor Air Quality and Ventilation ($32)

If you're a professor or faculty at a university or college, there's a variety of resources available for you and your students. If you're a student, there's limited grant money available for research assistance if you use an ASTM standard in your research.

This is my Accountability Dalek.

I'm doing this blog post as an extension of my review of this super-fun product on Amazon. 

I have this freaking adorable Dalek sitting on my computer desk, positioned so that I can see the Dalek's "head" over my laptop. 

My Accountability Dalek in action. Watching me work.

Every now and then, when I am bored (Gasp! Say it isn't true!) or needing to smile, I squish the Dalek to make it talk. The sticker on its midsection says "TRY ME!" On some stuffed animals, this is an invitation. With the Accountability Dalek, it's a direct challenge. 

"Exterminate! Exterminate!" I like to play that one when people are getting a little snippy on the phone. If you haven't watched Doctor Who, you're missing out. See a clip here. Summarizes the show quite nicely.

"You would make a good Dalek." I sometimes use that one when I am feeling particularly robot-like or like my hands are glued to my ergonomic keyboard. It reminds me to get up, move around, look around, and experience the world in person, not just through Google.

"You are an enemy of the Daleks! You must be destroyed!" I like to play that one when I break free of my computer and go do something that involves my brain and my body. Or when I am working on something creative.

Mostly, though, the Dalek watches over me and I can feel it silently judging me if I goof around on the Internet too much or get distracted from my report writing and data analysis. 

Everyone should have an Accountability Dalek. 

Lots of BLUE for the Accountability Dalek.

Plus, the Dalek is blue, which is apparently the color of honesty, trust, and dependability in business psychology. It makes you remember what business should be about and what kind of person you want to be. All this in a goofy Doctor Who stuffed robot. We all have to find meaning somewhere, yeah?

Buy yourself one, if you dare. 

Industrious Hygienist Holiday Safety Tip #1: Dogs do not mix well with fireworks.

This is Shadow, my 3.5-year old Alaskan Malamute. 

Shadow at 6 months.

Just kidding, this is Shadow. I just wanted to show a picture of him as a puppy. He's ginormous now. 

Shadow on a walk in Prescott Valley - controlled burn in the background.

Shadow is not a fan of New Year's Eve. He hates fireworks. New Year's Eve and Independence Day rank as his least favorite holidays. Some tips for a pet-friendly New Year's party here.  

My end of year cartoon (doubled as a holiday card for clients, colleagues, friends, and family):

The Industrious Hygienist and Shadow enjoy New Year's Eve together. 

We'll be spending New Year's Eve cuddled up in bed, with Shadow alternating between spastic races around the house and cowering next to us in the bedroom. Fun times in the Bliss household!

Wishing all my loyal readers a safe and fulfilling 2014. 

My (Late) Grown-Up Christmas List

I've been planning this blog post for about a month now, but (of course) couldn't get to it until today. One of my favorite Christmas songs is Amy Grant's rendition of "My Grown-Up Christmas List." (Ignore the fire safety issues in the video if you watch it.) It seemed especially poignant this year, so I decided to make my own list of things I am hoping will occur in the future.

I re-wrote the song to fit my wishes. Yay for creative license! Sort of an open letter to the OSHA and NIOSH Santa or other wish-granting djinn. Since it's by the Industrious Hygienist, there's a slight element of sarcasm mixed with my true wish for all workers to come home safely to their families.

"Grown-Up Christmas List"

Do you remember me 
I worked for you, you see 
I wrote to you on disability


Well I'm all healed-up now 
But still need help somehow 
I'm unemployed
But still so full of dreams


So here's my working wish
My grown-up Christmas list
Not for myself
But for a world in need


[Chorus:]
No more lives thrown away
That workers have a say
And speak up for their rights
Everyone would be well-trained
And want to do their best
And keep each other safe
This is my grown-up Christmas list


As children we believed
That parents would come home
To happy families
Without injury


Insurance surely sees
That claims and penalties
Can never heal a hurting human soul


[Chorus]


What are these concepts called
Prevention and respect
Maybe if we work together now
We�ll learn who we should protect

[Chorus]


So that's it...my wishes. Education, training, respect, and proactive approaches to health and safety for every worker. By the way, rhyming with safety terms is surprisingly difficult.

Look for the annual Industrious Hygienist end-of-year cartoon tomorrow!

No more weekly inspections of mechanical power presses?

Link to full news release here. Link to Federal Register notice here.

OSHA's most recent national news release discusses outdated or obsolete regulations.

On November 20, 2013, OSHA issued a rule with a notice of proposed rule-making to revise the requirement for weekly inspections of mechanical power presses.

These presses are used to punch holes in and form/assemble metal and other materials. When the presses are not properly maintained or damaged, workers operating the presses can experience injuries on their hands, and arms.

Per the Federal Register notice: "OSHA is revising a provision that requires employers to develop and maintain certification records of periodic inspections performed on the presses by adding a requirement that they develop and maintain certification records of any maintenance and repairs they perform on the presses during the periodic inspections. [...] OSHA is removing the requirement from another provision that employers develop and maintain certification records of weekly inspections and tests performed on the presses." 

OSHA believes that removing the requirement for documented weekly inspection and test certifications will save 613,600 hours of unnecessary paperwork time for businesses. Pending no significantly adverse comments, the final rule will become effective on February 18, 2014.

If this raises your hackles, you may submit comments electronically at www.regulations.gov.

The proposed rule-making would modify the existing standard's maintenance and repair requirements to be in line with the ANSI standard for mechanical power presses. ANSI B11.01-2009 requires that maintenance and repair be completed before the press is operated, and that the entire machine be "certified" as being maintained and repaired properly prior to use.

Thoughts on OSHA's proposed new rule for improved tracking of workplace injuries and illnesses

See the full news release from OSHA here.

After the release of the 2012 Occupational Injuries and Illnesses report was released earlier this month, OSHA posted a news release about a proposed new rule relating to record keeping.

The 2012 Occupational Injuries and Illnesses report estimated that 3 million workers were injured on the job during 2012. 

In the proposed rule, OSHA wants to add a requirement for businesses with more than 250 employees, who already keep records of workplace injuries and illnesses, to electronically submit their injury and illness records to OSHA each quarter.  OSHA also wants to add a requirement for businesses with 20 or more employees in high-hazard industries to submit their summary of work-related injuries and illnesses (OSHA Form 300A) electronically every year.

These efforts to improve the transparency of government are interesting.

From a faculty/educator perspective, if the government is able to publish the injury and illness data more than once per year, it will allow safety and industrial hygiene students and educators to focus their attention and perhaps lead to some interesting research or meta-analyses.

Telepests and National Safety Council Infographics

I learned a new term today: telepest.

Since launching my new website for Spore Consulting, I have been receiving all sorts of fun calls to the number I listed on my WHOIS domain registration, which is to be expected. Each time I receive one of these calls, I look the phone number up on the internet to make sure it is not a potential client.

The number I received a call from today had a bunch of listings and complaints as a "telepest." Apparently a telepest is informally known as an annoying phone number that calls you frequently (i.e. robot telemarketers and unsolicited/spam calls).

Who knew? There's a word for everything. :)

Have also been catching up on my reading and wanted to share the following National Safety Council (NSC) infographic on the "Top 10 Most Frequently Cited OSHA Violations." Download your own copy off the NSC Blog. There was supposed to be a way to embed the infographic on my blog, but I am not enough of a Blogger ninja to figure that out.

NSC Infographic about the Top 10 Most Frequently Cited OSHA Violations.

In order of least to most citations (per NSC):

10 - Machine Guarding
9 - Electrical: General Requirements
8 - Lockout Tagout
7 - Ladders
6 - Powered Industrial Trucks
5 - Electrical: Wiring Methods
4 - Respiratory Protection
3 - Scaffolding
2 - Hazard Communication
1 - Fall Protection

In other news, my research into coal mining in Lancashire in the 1890's has been super-enjoyable. The character development and storyline mapping for my alternative history/steampunk series fiction that incorporates the history of industrial hygiene and workplace safety is underway.

While preparing for my first OSHA 30-hour for General Industry course, I also discovered the CDC Small Business Resource Guide. This CDC website has documents from Federal OSHA, state OSH programs, and international resources (Ireland and UK) to help small businesses develop an effective safety and health program.

Feeding my indie beast...big changes ahead!

Exciting news: the Industrious Hygienist has decided to take the plunge and venture out on her own in the perilous world of consulting. Meet Spore Consulting, LLC.

Why Spore?

Spore Consulting, LLC ("Spore" for short) embodies the idea of a microbial spore. Bacteria form spores to help them get through tough times and fungi have spores as part of their reproductive cycle. In fungi, spores are small biological particles that contain everything the fungi needs to reproduce when conditions are right. 

So, we figured Spore stands for: small, resilient, everything you need for success. 

In addition to occupational and environmental health & safety consulting, the Industrious Hygienist will be working more on creative (i.e. nerdy) things:

• Sock Puppet Safety 
• Safety educational videos featuring sock puppets, to be posted on YouTube
• Steampunk fiction featuring the Industrious Hygienist 
• Safety checklists and safety posters that are visually appealing
• Industrious Hygienist mangas

So stay posted and watch for more fun stories and cartoons. 

Mushrooms = fungi. Photoshop is a dangerously fun thing.

Susan Harwood Grant Recipients for 2013

As of September 16, 2013, OSHA has announced the latest round of Susan Harwood Training Grant recipients. OSHA awarded $10.1 million to the various recipients. There's a few that the Industrious Hygienist is really excited about.


From the "targeted topic" list of recipients:

Alaska Marine Safety Education Association, Sitka, AK
Ergonomics, award of $105,300
"The grantee will deliver training on ergonomic hazards for workers in the commercial fishing and fish processing industry. The goal is to educate workers on the basics of ergonomics including assessing ergonomic hazards in the workplace, redesigning work space for improved ergonomics, prevention of musculoskeletal disorders (MSDs) and exercises for preventing and relieving symptoms associated with MSDs. Training will be offered in English, Spanish and Vietnamese."

Why am I excited? The ergonomics recommendations will be focused on the commercial fishing industry, and Alaska Marine Safety Education Association (AMSEA) seems to have excellent outreach to their target population. Their website is informational and well-organized.
Plus, I have an Alaskan Malamute, so our household is a fan of many Alaska-related things. 

National Jewish Health, Denver, CO
Multiple Topics, award of $105,300
"The grantee will develop and deliver training on multiple topics to automotive industry workers. The training will cover hazards to which automotive repair workers, mechanics and technicians can be exposed to in certain jobs including crystalline silica, asbestos, lead, hexavalent chromium and physical hazards that can cause respiratory disease, neurologic problems, skin disorders, allergies, cancer, hearing loss, eye injuries, and ergonomic injuries."

Why am I excited? National Jewish Health has been rated the leading respiratory hospital in the nation. Their mantra of "Science Transforming Life" is at the core of their research activities, which encompass aspects of mycobacteria, environmental health, occupational health, and allergens, all things which are near and dear to the Industrious Hygienist's heart. Interesting note: National Jewish Health first opened in 1899 as a tuberculosis sanitorium. 

Massachusetts Coalition for Occupational Safety and Health, Dorchester, MA
Work Place Violence, award of $104,196
"The grantee will offer work place violence training for young workers and small businesses employing youth. Training will include an introduction to hazard identification and control; worker rights and responsibilities; and the identification and mitigation of work place violence in the retail and healthcare settings. Training activities will utilize participatory learning methods including interactive discussion, case studies, and role playing."

Why am I excited? The MassCOSH group seems to be extensively collaborative and holds a leadership academy for teen workers to promote job safety. Some of their core initiatives are: "Healthy Schools Initiative," "Immigrant Worker Center," "Teens Lead At Work," and a focus on union education and organization. They have articles, reports, and fact sheets from their educational findings. 


In the "capacity building developmental grant" list of recipients:

Board of Regents of UW System for Univ. Wisconsin-Milwaukee, Milwaukee, WI
Safety and Ergonomics Follow-On, award of $148,400
"The grantee will provide training on safety and ergonomics to small utility employees and contractors. The training will target small businesses, non-English speaking/limited English proficiency, minority and other hard to reach workers. The grantee will also develop training materials for employees in the green/renewable power-generation (solar, wind and biofuel) sector in English and Spanish."

Why am I excited? The green/renewable power generation sector needs training and hazard assessments for the work being conducted at the generating sites. 

SEIU Education and Support Fund, Washington, DC
Health Care Industry, award of $177,250
"The grantee will present training to workers employed in the home care, nursing home, and hospital sectors of the health care industry. The target audience will include non-English speaking/limited English proficiency, non-literate and low literacy workers, immigrant and minority workers. The grantee will develop and present a Hazard Communication (HazCom) course in English, Spanish, Chinese, and Russian."

Why am I excited? Healthcare health and safety is my specialty, and since OSHA announced its National Emphasis Program on Nursing Homes and Personal Care Facilities in April 2012, I've been hoping for someone to develop this kind of training.

Thanks to OSHA for offering the Susan Harwood Training Grants.