Safe Chemicals Act of 2011

Have you ever evaluated whether the household products you use contain hazardous industrial chemicals? Have you determined whether they’re safe to use? Most likely, you’ve answered ‘no’ to both…don’t feel as if you’ve failed for the manufacturers of these products haven’t evaluated all their products either.

The Safe Chemicals Act of 2011 has been introduced to legislation as an amendment to the Toxic Substances Control Act (TSCA). The purpose of the proposed Act is to “ensure that risks from chemicals are adequately understood and managed.” It would require manufacturers to ensure the safety of everyday household products before they enter the market and subsequently your household. Currently, evaluation is only done when EPA receives information suggesting that the material may pose a health risk.

The Act reports that (1) each year human beings and the environment are exposed to a large number of chemical substances; (2) more than 3 decades after the enactment of TSCA, people and the environment in the United States are still exposed to thousands of chemicals whose safety has not been adequately reviewed and may harm health and the environment; (3) the incidence of some diseases and disorders linked to chemical substance exposures is on the rise; (4) biomonitoring of chemical substances in humans reveals that people in the United States carry hundreds of hazardous chemicals in their bodies; and (5) the concentrations of certain chemical substances that persist and accumulate are increasing in the environment and in human bodies and are found across the world, including in the remote Arctic. All good reasons to support this Act.

Information that will be required to be provided by the manufacturer if the Act is passed includes (1) carcinogenesis, mutagenesis, teratogenesis, behavioral disorders, cumulative, synergistic, or any other effect pertaining to exposure to the chemical substance; (2) presence of the chemical substance in human blood, fluids, or tissue; and (3) information pertaining to bioaccumulation; persistence; acute toxicity; subacute toxicity; chronic toxicity; and any other characteristic may present an adverse effect. How this information will be provided is unknown. It is hoped that the information will be included on the product label or readily and easily accessible to the consumer.

While this information is typically provided to employees in the workplace, it is not currently provided to homeowners. Providing information to everyone, whether at home or work, is expected to help reduce potential exposures and address some of the issues reported above.

Proper CIH Signature in California

Certified Industrial Hygienists (CIHs) that "create reports, opinions, or official documents prepared for submission to an employer, government agency, or other consumer" must affix a stamp and signature on such final documents. This is required per California Business and Professions Code Section 20702.

Any individual, company, or other organization that hires a CIH in California should review final documents to ensure that both a stamp and signature are included. The stamp should include an identification number and name of the certified individual. This provides the consumer some assurance that work has indeed been completed by a professional certified by the American Board of Industrial Hygiene (ABIH).

While I'm certainly not suggesting that there are individuals conducting work under the CIH moniker that are not certified, it is possible. consumers should be aware of titles that could mislead them in thinking an individual is a CIH. A couple examples are “competent industrial hygienist” or “consulting industrial hygienist.” Neither has the same training or expertise as a licensed CIH.

Not Making the Grade…Cal/OSHA

On September 28^th Federal OSHA distributed report cards to each of the 27 State-run OSHA programs…25 were given incompletes and 30 days to develop a written plan to correct identified shortfalls. Cal-OSHA was identified as one of the failing programs. Here’s a link to Cal-OSHA’s “report card” for FY2009.

http://www.osha.gov/dcsp/osp/efame/ca_efame_with_appendices.pdf

Beginning my career outside of California, I often heard how California was “cutting edge” in the Occupational Safety and Health field. When reviewing the list of failing programs, I was disappointed to learn that Cal-OSHA didn’t “Pass.” I was most disappointed that the shortfalls (missing documentation and closing times of investigations that are “significantly higher than the national average.”) were primarily budget related. I know this is not uncommon amongst California agencies at the moment, but being short staffed by 45 people is significant. Add in furloughs and I’m left wondering who’s answering the phones?

Missing documentation and slow moving investigations are a problem. However, I don’t necessarily agree that points should be subtracted for Cal-OSHA not meeting Federal Procedures (OSHA FOM). Maybe California’s “Cutting Edge” approach is better? I’m not sure what criteria would be used for such a comparison. Either way, this is a very argumentative claim.

So what does this mean? The “report card” specifically noted deficiencies in 3 standards: (the Employer Payment for Personal Protective Equipment, the Clarification of Employer Duty to Provide Personal Protective Equipment and Train Each Employee and the Final Rule on Electrical Installation Requirements). Cal-OSHA must provide a written plan as to how necessary corrections will be made (if they can find the staff hours…bad time for that jab?). It may be that changes to Cal-OSHA regulations are made. Stay tuned…

Chemicals of Concern

OSHA has established permissible exposure limits (PELs) for hundreds of chemicals. Unfortunately, the PELs were set in the 1970's using science / research from the '50s. OSHA has opened the door to receive comments on "Chemicals of Concerns." Comments can be provided at:

http://www.osha.gov/pelforum.html

The purpose for collecting such information is to help OSHA develop pertinent solutions for reducing worker's exposures using more up to date information for more prevalently used chemicals. Be sure to provide your feedback BY AUGUST 27, 2010.

If you have questions or would like assistance in determining which chemical constituents to include, please contact me at brent@peakih.com.

Helping you better understand potential hazards...

Welcome to my blog. My primary goal for this blog is to share information and provide a forum for discussing ways to identify, assess, and control hazards that may exist at your place of work, your home, or somewhere in between. Information will be provided on a diverse selection of industrial hygiene, health and safety topics. I welcome your comments, feedback, and ideas for posts! Stay tuned for my first post on a topic…