Updated Permissible Exposure Limits, globally uniform MSDS, and more focus on preventing occupational illness and injury top the policy priorities of the nation’s occupational health and safety professionals.
The American Industrial Hygiene Association (AIHA) released its 2011-2012 priority list after a survey of its members in the occupational and environmental health and safety profession. AIHA is a private, nonprofit member organization comprised largely of scientists and engineers who focus on workplace health and safety.
The new AIHA recommends cut across all regulatory jurisdictions and business sectors.
Topping the list is a call to update the nation’s list of Permissible Exposure Limits for chemicals used in the workplace. PELs are consensus-based limits that indicate how long an individual can be exposed to a particular substance without experiencing harmful effects.
The Occupational Safety and Health Administration sets PELs, but it has established limits for less than 25% of the chemicals now estimated to be in use in the workplace. Furthermore, fewer than 30 of those limits have been updated in 40 years. OSHA recently initiated an effort to review all of the PELs in the current list and establish first-time limits for harmful substances that currently have no exposure limit.
“[M]any PELs have not been updated since the 1960s and 1970s,” AIHA says. “Science in this area has matured, but the PELs have not.”
The group says it “continues to work with OSHA, Congress and others to reach a consensus on the best way to update the PELs.”
Injury and Illness Prevention Program
AIHA supports the need to define effective occupational health and safety programs and calls hazard assessment and implementation of a written safety and health program “parts of minimum acceptable professional practice on any work site.”
As such, the organization has been working with OSHA to develop a rule to require employers to establish and maintain an Injury and Illness Prevention Program. This involves identifying and controlling hazards as well as planning, implementing, evaluating and improving processes and activities that protect employee safety and health.
MSDS Globally Harmonized System
AIHA supports adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as a step toward improving the accuracy of MSDS. Developed and managed by the United Nations Sub-Committee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals, GHS is a system for standardizing and harmonizing the classification and labeling of chemicals.
The GHS itself is not a regulation or a standard. The GHS Document (referred to as "The Purple Book") establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system. The elements in the GHS supply a mechanism to meet the basic requirement of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate.
AIHA also calls for improvement in hazard communication, calling it “a crucial element in protecting workers and others in case of national emergencies.”
Professional recognition has been a public policy priority for AIHA since 1993. The group is concerned about what it calls “the continued influx of specific occupational health and safety titles that are awarded by non-accredited bodies and the attempt to recognize these titles in various policy-making activities.”
“Professional recognition/title protection allows industrial hygienists and others who have met minimum educational and experience requirements (such as certified industrial hygienists and certified safety professionals) to be legally defined and recognized as competent to perform certain work without the need for additional requirements. “
OSHA Reform and NIOSH Recognition
Each year, Congress introduces and considers legislation to amend the Occupational Safety and Health Act, including criminal penalties, whistleblower protections, expansion of coverage, and the Voluntary Protection Program. AIHA says it supports these efforts “if changes provide added protection for workers.”
The association also supports efforts to protect the National Institute for Occupational Safety and Health (NIOSH) “from attempts to diminish the importance of the Institute and its research” and supports adequate funding for both OSHA and NIOSH.
Calling accredited laboratories “the best way to ensure that test samples of potential workplace hazards are analyzed correctly,” AIHA “continues working to see that the AIHA laboratory accreditation program is internationally recognized and noted in federal and state legislation and regulation as one of the programs with recognition and acceptance.”
Other priorities include updating OSHA noise and hearing standards, which is also currently underway; more attention to combustible dust; OSHA compliance requirements for federal contractors; and expansion of OSHA coverage to all employees.
AIHA surveyed its members online in October. The organization says it will review existing white papers and position statements, as well as draft new position statements, to determine the appropriate response to each issue it cites.
Founded in 1939, AIHA is the leading association of occupational and environmental health and safety professionals, with more than 10,240 members representing a cross-section of industry, private business, labor, government, and academia.