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.
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!