Tuesday, September 9, 2014

Checklists and audits are nice but would someone please fix the workplace?

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!



Jas Singh
Hawaii, USA






Monday, January 27, 2014

Your Perfume is Making Me Sick

Chemical Sensitivity Issues in the Indoor Work Environment

In the 1990’s I was managing a small group of Environmental Health and Safety (EHS) professionals on the West Coast, USA. The group that I had inherited, as a result of an acquisition, was divided into two service areas:

·         Environmental management

·         Health and safety with focus on industrial hygiene

Each department had a manager and a secretary. The term secretary in those days, was still considered honorable because the term “administrative assistant” was not yet common.  Besides my overall responsibilities as a business manager, I was also acting (please don’t laugh at the word “acting”) as the Industrial Hygiene Department Manager. My secretary Linda, by default, was the IH department secretary.

Joanna, the environmental department secretary, and Linda were miles apart on everything. We shall not go into those details but suffice it to say they quickly developed mutual disliking. Being good professionals, however, they tolerated each other except for one thing – they hated each other’s perfume choice. Unfortunately, they both used generous amounts of their favorite aroma.

Linda, being a little closer to me, complained bitterly about Joanna’s “cheap perfume” and the quantities she was using, forgetting that she herself could be accused of the same. Having never been trained in the art of “perfume arbitrations,” I felt utterly helpless to deal with this matter so the problem escalated.

            One morning Linda came to my office and said:

            “Can you smell it? I cannot stand her perfume. It is making me sick. You can ask others in the office. I love my job, but if this continues I will have to update my resume.”

It suddenly dawned on me that a full-scale perfume war had erupted in my office. It was the kind of crisis for which I had received no prior training and I could not find any training or courses on the subject. Any time I tried searching the available literature I found “Indoor Air Quality” which shed no light on the crisis at hand.

At first, I refused to be involved and advised Linda to take Joanna to lunch (at company expense) and to do the “pinky patch up.” This irritated Linda to no end and she accused me of trivializing the issue. She had come to believe that I would always agree with her judgment on such office issues. She assumed that she was the “mother hen” in the office although the title would not have pleased her. She never told me this but told people in the office that back in her younger days in her native Midwestern town she was some kind of a beauty queen. For proof she showed them pictures of her modelling poses wearing cowboy hats and holding a Colt 45 pistol while clad in scanty clothing. Senior employees advised me not to view the photos, which made me more curious, but I heeded their advice. They were smarter than me. Nevertheless, it was easy to imagine that 25 years earlier she could have justified the proverbial description of “all-American, wholesome farm girl from the Midwest.”

The perfume war dragged on for some time without causalities until one day suddenly all hell broke loose. 

Joanna, who was no lamb herself, finally had it with her colleague. She was tired of being pushed around by Linda and decided to take action. One Monday morning she came to the office early, went to Linda’s desk, which was just outside my office, and emptied half of her fragrance bottle right in her chair. Well, you can guess the consequences. When Linda came to the office a few minutes later and viewed the crime scene she hit the ceiling. Thank God I was not around. I arrived 5 minutes later. As soon as I opened the door, Linda intercepted me in the office lobby, got as close to my ear as physically possible and yelled:

“Aren’t you going to do something?”

            “What do mean? I do lot of things. Do you think I come here and suck on my thumb every day?”

“Jas, please save your jokes for another day. Come and see what your ‘valuable asset’ (my favorite phrase to describe my able above average staff) did to trash my chair.” Then without any response from me, she grabbed my arm and dragged me to her desk.

            The place was reeking, I mean reeking with the smell of perfume mixed with high concentration of ethanol, and God knows what else. Linda continued:

“It is so strong and pungent and there is so much of it! The woman is not wearing perfume. She is wearing curry powder mixed with horse radish.”

            I was glad she said horse radish but I still objected to this and told Linda:

“But I like curry powder. Every time I smell curry powder, I get hungry.”

            “Then go to the source and have a feast…” She started to say something unsavory, hesitated, and completed the sentence differently.

“Go ahead and have your fill of it and don’t worry, tomorrow I will bring you a bucket of chicken curry for lunch.”

Thus assured, I asked Linda to open all windows in the fully air conditioned office, to calm down, and I promised to do something.

Joanna was watching all this from her office on the other side of the building although she could not hear anything except some high frequency tones on the right side of the octave band.

            After a couple of hours I called Joanna to discuss the crisis. I did not raise my voice (I was proud of this) and promised “to do something.” She thanked me. I suggested to Linda to take Joanna to lunch (at company expense) and discuss a peace treaty. She declined.

The calm before the storm

The situation was far from resolved. Foolishly, I thought that the smart strategy was to ask Linda to be more patient, co-operative, and put up with it to keep peace and again reiterated my promise to do something. Then feeling overconfident about my good relationship with her, I told her that she did not always behave correctly, not realizing that it may have been received as scolding. Linda did not say anything and left the room.

            An hour later she stormed into my office, closed the door and poured it on. “I guess I am the witch around here. I will clear my desk as soon as possible and you can find another ‘valuable asset,’ competent and sweet natured.” Then she stormed out as fast as she had stormed in. I sat stunned in my chair for a while wishing I was facing a familiar chemical crisis rather than the perfume crisis.

The thought of two beauty queens duking it out (battling) with perfume guns saddened me. 
             I went back to Linda’s desk in another attempt at peace making. It was too late. Linda was not in her chair. She was sitting on the floor in the corner clasping her head between her hands, sobbing, and shaking. It looked like she was breathing with some difficulty. She was not pretending. Linda was in distress. One of the employees immediately called the fire department. They came swiftly, rendered some emergency treatment, and suggested she be sent home. They told me she had overdosed herself with an extra pill or two of some painkiller. I suspected it was more than that. Could it be a synergistic effect between exposure to ethanol, a diluent in the perfume, the perfume itself, and the stress induced by my “perceived” scolding? I chose to go with the medic’s explanation of a drug reaction

Her husband, a prince of a man, arrived and promptly took her home. Before leaving, he pulled me aside and confided. “Jas I owe you an apology. I know that you are good to Linda. She tells me all the time what a good boss you are, but I should have warned you, Linda’s TLV for criticism is almost zero.” Lesson learned.

Indoor environmental quality

(But why do we call it indoor air quality?)

The two-decade old perfume war came alive in my memory just recently when I came across an excellent article titled “Allergic to Life” by Jill Neimark in the November 2013 issue of the “Discover” magazine. The article was about chemical sensitivity focusing on the research done by Dr. Claudia Miller, an Environmental Health expert at the University Of Texas School Of Medicine in San Antonio and co-author of the book “Chemical exposures; Low Levels and High Stakes.” Doctor Miller descries this illness this way:

“First a susceptible individual gets sick after toxic exposure or exposures. But then, instead of recovering, the neurological and immune system remains damaged, and the individual fails to get well.”

The article prompted me to think about recent progress made in the field of chemical sensitivity. This is a phenomenon, where a significant number of people appear to be clinically affected by exposure to very small concentrations of a multitude of chemicals which when viewed through the “TLV lens,” may not warrant attention.

Chemical sensitivity, also referred to as “multiple chemical sensitivity,” is not a new issue. In the past, I had casually dismissed such suggestions as without merit and lacking scientific base, but I feel differently now. I am beginning to recognize the issue as legitimate and worth considering when assessing the quality of the indoor environments while recognizing that there are not many practical remedial measures at this time to address the problem.

            I urge my readers to study Dr Miller’s work.  But at this point, I want to move on to my pet peeve – poor indoor air quality investigations.

Indoor air quality (IAQ)

 I dislike the term Indoor Air Quality (IAQ) which, unfortunately, has come to represent the quality of the indoor environment which should involve much more work than just sniffing the air.

Calling this emerging environmental health issue an “IAQ” has reduced this genuine workplace hazard concern that requires a high degree of professional expertise to investigate, into an air sampling exercise and a numbers game which is focused on half a dozen parameters such as CO, CO2, formaldehyde, particulates, temperature, and humidity. This is supplemented with (but not always) a few samples of total hydrocarbons and total fungal spores, dead or alive. Chemical sensitivity, mental stress related to overtime, few breaks, a toxic workplace culture, and questionable ethics are totally ignored. It is as if every stress in the workplace is airborne.

I do not want to imply that sampling the air is a wasteful exercise. High-quality, statistically valid data is basic to the professional practice of industrial hygiene, but please do not recommend air measurements as panacea for every employee complaint related to an unhealthy and stressful work environment. All stresses in the workplace are not floating around in the air. Earth’s gravity is powerful!

            I realize that most industrial hygienists (myself included) are not experts in dealing with multitudes of issues that make the workplace stressful and unhealthy and the resultant employee complaints and dissatisfaction. However, as professionals we have the obligation to raise these issues, make judgments, and recommendations and refer to experts when we lack expertise ourselves.

What makes us think that we will satisfy employee concerns and make the workplace healthy and stress-free by performing thousands of CO and CO2 tests in the air? Yet every time the problem of “unhealthy” workplace comes up, many hygienists pull out the “cookie-cutter” IAQ protocol from their magic hat. Strangely, many employers readily open the wallet and receive reams of airborne ambient CO, CO2, THC data which an experienced hygienist would have estimated within two (but certainly three) standard deviations within hours of entering the premises. An additional twenty pages of numbers is not likely to alter decision making.

Not too long ago I was asked to peer review a thick IAQ report.  Thick because it had 20 plus pages of sampling data (half a dozen airborne chemicals and dead spores) and one page of conclusions and recommendations. Tens of thousands of dollars were spent (I estimate USD $50, 000) on generating the numbers that provided no clue to the employee distress.

Following were the conclusions of this expensive study. What value was derived from the investment and what lessons were learned to make the work place better?

Please review below. I will let you be the judge.  See my comments in italicized letters.

“Section VI: Conclusions:

1.      All the samples collected were below the IAQ limits established by the Department of …….

2.      All the samples collected were also below the TLVs established by the ACGIH (Really? What a shock!)

3.      ABC’s IAQ investigation did not find any evidence of worker stress from Indoor Air Quality (Great! $50K well spent.)

 Section VII: Recommendations

ABC recommends that additional IAQ assessments be conducted anytime there are any changes in the building or any additional employee complaints are received (Okay, but what about addressing the current complaints that triggered the current survey?)

The report did not even acknowledge that there are multiple factors that lead to employee dissatisfaction discomfort and health impairment. Unfortunately, the majority of the IAQ reports I review do not.

Friends, we industrial hygienists have the duty to demonstrate the value of the work we perform. Merely reporting a number, whether required by a regulation or not, is not practicing industrial hygiene. I do realize that sometime the clients (internal or external) specifically may not want a hygienist to say more.

Well, I am scratching my head on that and searching for advice.

Do you have any suggestions?

Jas Singh, Ph.D., CIH
JAS International LLC
EHS Consulting and Training
Kamuela, Hawaii, USA
January 27, 2014
Email:  jas@jas-intl.com

Editing by:  Gregory Beckstrom
Illustrated by:  Carol Nagan

Saturday, January 11, 2014

There comes a time in life when one must decide what to do with the rest of your life.  What do you most want to be remembered as? What is the legacy you want to leave behind?

In my case, there is no pondering. I want to spend the rest of my professional years (next 12 years) in IH education and training, sharing my knowledge and experience of IH, mentoring, and promoting this wonderful profession whose main reason for being is protecting lives.

Jas Singh PhD, CIH