A few years ago I was teaching an
internal company workshop in Europe to motivate colleagues from several
countries to become more involved in Industrial Hygiene. The program was
received with enthusiasm and supported by the local managements. Half a dozen
participants expressed desires to address industrial hygiene aspects in greater
depth when they performed the “EHS assessments” in which they were increasingly
engaged. This was most encouraging. I was having impact. I was getting more people
interested in Industrial Hygiene.
My most enthusiastic student was a
bright young woman with an environmental management degree from a well-known university.
She pulled me aside and said, “That was a good workshop. I am
interested in pursuing IH as my main specialty. For the next three months I
have opportunity to do some comprehensive IH for three of our major clients.”
“Awesome,” I replied. “What
assistance can I provide to help you prepare for the opportunity?”
“You could give me an IH checklist
as a starter. You probably have the best checklists by now.”
She winked implying that I have
been around for a while.
Her checklist question plummeted my
enthusiasm but I did now show it. I should have anticipated it. “What is the
nature of business of your prospective clients?" I asked.
“Two of them are big
multinationals. One is a mining company and the other one is in the oil and gas
business. The third, and perhaps the most interesting, is a midsize specialty
chemical company. The processes used by this company involve very complex
chemistry but this is not a worry. We have two chemical engineers on staff and
myself. I have a good background in
chemistry.”
I had not anticipated that the “checklist”
would be the priority for the projects on hand. I should have. People are increasingly relying
on checklists to solve environmental, safety and health problems because few
have the motivation to dig deeper. I hid my disappointment and said, “You know,
there are lot of checklists and audit protocols. Some are good and some are not worth lining a
bird cage.”
I regretted saying the last sentence but that
is the way I felt. Fortunately she did not get it. Colloquial English was not
her best suit although her English was impeccable for a person from a
non-English speaking country.
“Checklists can be of value when
performing environmental assessments specific to water quality, waste
practices, management practices etc. but I have never seen an all-encompassing
Industrial Hygiene list suitable for every occasion. What would be a good checklist
for mining will not be suitable for oil and gas and certainly not for the specialty
chemical producer. Any IH checklist I
can give you will be general. It will have questions like: Do you maintain a chemical inventory? Do you
have training and sampling programs and pre-employment and routine physicals? Etc.
These are important questions to ask but the overall content and coverage is so
general and non-specific and that it will fail to address the vast differences
in chemical behavior, control concepts and impact on worker health and
well-being.
I realized my rant on checklists
did not satisfy her. She still wanted the magic list.
“I will contact you after I find
more details” she said in a hurry.
We shook hands. She thanked me
again. I never heard from her again.
My favorite IH
conferences
There are two professional
conferences every year I never want to miss. One is the annual conference of
the American Industrial Hygiene (AIHA) which I first attended in 1974 and have
not missed since.
The second is the Annual Yuma
Pacific IH Conference usually held in San Diego. For the quality of content and
sheer camaraderie and fun nothing beats the Yuma-Pacific AIHA meeting. This conference gets better every year no
doubt because of leadership of Anna Davis, who accepted the responsibility to
keep the venerable institution started by the late George Clayton, alive and
well. On a good day, during the meeting, you could run into several past AIHA
presidents, an ACGIH Chair, past OSHA Director or two and some of the original
pioneers in the profession. Yuma Pacific
is only one of the two IH forums I know where you can express an opinion
without concern for liability, retribution or being quoted out of context even
in the presence of lawyers (there are lawyer members). It is a high level free
for all event.
The 2012 meeting was no exception. The
program was structured. The speakers
were top notch. To my disappointment,
however, all the technical presentations, were on assessments and audits. I was
hoping for few success stories on problem solving, engineering solutions, and
process modification/tweaks to minimize exposure.
Several members noted the same. The
members decided that that he next year’s (2014) meeting must emphasize
controls; engineering controls at that. Presided by Del Malzahn CIH, the 2014
meeting featured two days of presentations on “fixing” the workplace. Professor Robert Soule (retired), University
of Indiana, Pennsylvania, explored the reasons why engineers are not entering
the IH profession and why only very few of the experienced non-engineer IH’s
seem interested in controls. The current emphasis is on audits and assessments.
Don’t get me wrong. Assessments and
audits are necessary to formulate action plans but in the IH practice today,
audits are becoming the end product. Some assessments and audits do go to the
sampling phase to better characterize the workplace but die a sudden death soon
after. It is as if unknowing to us all, the Industrial Hygiene has been
re-defined as an auditing profession.
If this sounds alarming to you, have
you ever tried to find an industrial Hygiene professional engineer who can “design”
an industrial ventilation system from scratch? It will not be easy. Please do
not remind me of the less than a dozen such individuals we all know of. Are we
leaving this part of IH to others? And who are they?
Then there is the German approach
which is to go straight for the engineering fix if an exposure risk is
indicated. This is very effective, especially in good German engineering hands,
but it can be expensive and overkill. Audits and detail assessments are needed
but the IH profession needs to focus on fixing the work environment and not
merely studying it.
Audits Galore
There are a large variety of
audits, some with impressive and innovative names that address worker safety
and health, corporate social responsibility and sustainable workplace. Most do
not address industrial hygiene in a meaningful way.
I would be happy by the preponderance of the
checklists and audits if they were designed to actually improve the
workplace. If the objective of the audit
or assessment was purely bureaucratic, either to satisfy a government mandate
or a corporate formality, maybe some purpose would be served. If the exercise,
however, is to make the workplaces safer and healthier, most such audits do not
achieve the goal.
More recently I have been intrigued by the CSR
audits. Corporate Social Responsibility is a new and welcome concept in our
profession. It can encompasses many components that are a critical part of the
IH practice and can positively impact workplace safety and health. The CSR
audits being conducted today appear shallow and cookie cutter with little to
show for the effort. In some cases such superficial audits conducted by
unqualified checklist specialists have proven misleading and potentially harmful.
This issue was brought to focus by
Garrett Brown at the AIHA conference in San Antonio. Mr. Brown, who just
retired after 20 years as a compliance officer for Cal/OSHA and has championed
the health and safety causes in global supply chains as the volunteer Coordinator
of the Maquiladora Health & Safety Support Network since 1993, talked about
the clothing factory collapse in Bangladesh, the site of one of the biggest disasters
of our times in April 2013 resulting in the death of 1,135 workers. The collapse resulted from negligence of
health and safety practices. Brown, a Certified Industrial Hygienist and AIHA
Fellow, noted that of the several HS and CSR safety audits performed at the Bangladesh
clothing facility, almost every audit gave the doomed facility a “pass”. Some had
noted minor violations. None identified structural flaws or serious fire
protection deficiencies.
April 2005 Spectrum Sweater factory collapse
The Rana Plaza collapse- 2013 – terrible that there are so many collapse
photos to pick from!
The question arises: Why did they not identify these problems? Did
any of the auditors have expertise in structure failures or fire protection in a
meaningful way? Were shoddy construction
and structural deficiencies even on the audit checklist? Was there “Keep the
client happy” philosophy behind it?
Brown noted the following
deficiencies in the audits he came across in his AIHCE presentation. I reproduce
his list with his permission:
“Drive BY” and “Tick the Box” Inspections
Subcontracting actual inspections
Inescapable conflict of interest (“keep the client happy”)
You
be the judge!
Respectfully,
Jas Singh
Kamuela,