Design of measurement strategies for workplace exposures

Hans Kromhout

doi:10.1136/oem.59.5.349

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Design of measurement strategies for workplace exposures

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"Where there is no expert": author's response to the letter by Dr Topping
Hans Kromhout
Published on: 27 April 2016
Comments on article by Kromhout
Michael Topping
Published on: 27 April 2016

Published on: 27 April 2016
"Where there is no expert": author's response to the letter by Dr Topping
- Hans Kromhout, Associate Professor
Dear Editor
This letter is in response to the comments made by Dr Michael Topping with regard to my article on measurement strategies for workplace exposures.[1] His response is focussed at my introductory words on the development and promises of tools like COSHH Essentials and EASE.
His main point is that I would ignore the variety of competences and number of firms who use chemicals in the workplace...
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Dear Editor
This letter is in response to the comments made by Dr Michael Topping with regard to my article on measurement strategies for workplace exposures.[1] His response is focussed at my introductory words on the development and promises of tools like COSHH Essentials and EASE.
His main point is that I would ignore the variety of competences and number of firms who use chemicals in the workplace and that proper evaluation (with actual measurements of workplace exposures) would come with astronomical costs and would not be possible due to lack of expertise. Together with the Editor of the Annals of Occupational Hygiene, I question whether the introduction of tools like COSHH Essentials has contributed to the collapse of full-time training of occupational hygiene professionals in Britain through lack of demand for expertise.[2] As I pointed out in my paper, measurement strategies that involve workers in the sampling procedure can be very cost efficient and have shown to be working.[3] The claim that nobody has been complaining about controls being over precautionary after using COSHH Essentials is no justification. For instance, what if a company after applying COSHH Essentials is advised to take expensive control measures, while actual measurements show that exposure levels are well under the occupational exposure limits? With COSHH Essentials erring on the safe side this will most likely be often the case.
The comment that I would misrepresent the purpose of the EASE expert system is false. Dr Topping forgets to mention that EASE was developed not only for new substances but also for existing substances.[4] In addition I am aware of training courses have been given in my own country where EASE was propagated as a tool to evaluate substance exposure in workplaces. If this expert system is only to be used for risk assessment purposes, HSE should start labelling it with the phrase "not intended to be used as a tool to help employers control exposures in the workplace". However in the documentation that came with my version of EASE we can read "Modelled data may be derived from the general purpose predictive model for exposure assessment in the workplace described in this paper and called 'EASE'".[4]
The real problem with tools like EASE and COSHH Essentials is that they are not properly evaluated before they are launched into the occupational health arena. Peer review by an expert group established by the BOHS and support of industry and trade unions cannot replace the necessary scientific rigor of testing reproducibility and validity and having these studies peer-reviewed in scientific journals. Testing validity long after introduction of a tool, as happened with EASE,[5,6] would not have been tolerated when EASE would have been, for instance a medical diagnostic tool, or even closer to home an analytical method to measure styrene. HSE is apparently not too happy with the accuracy of EASE either, since, as far as I am informed, a project is underway to create a more valid expert assessment tool.
Even though Dr Topping justifiably suggests that the tools should be seen as complementary, the place of "structured data collection" remains unclear in his letter. One can deduct from the described use of EASE and COSHH Essentials that proper assessment of exposure by measurements would only have to take place at larger firms. Unfortunately, as we all know, that is not where the majority of workers perform their jobs. In my view tools like EASE and COSHH Essentials should be used in the initial judgement step and proper evaluation should always follow to prevent unnecessary investments or ill advised control measures. Given the enormous variability we have to take into account when evaluating chemical risks, we should never exclusively rely on generic tools that lack precision and even worse accuracy.
Finally, I would like to suggest renaming COSHH Essentials into "Where there is no expert". While staying in less-developed countries, I cherished my copy of "Where there is no doctor".[7] Nowadays, I frequent my GP who has access to more precise and accurate diagnostic tools. To me it is unthinkable that poor man's tools are being used to evaluate chemical hazards in a well-developed country as the UK.
References
(1) Kromhout H. Design of measurement strategies for workplace exposures. Occp Environ Med 2002;59: 349-354.
(2) Ogden TL. Editorial: Occupational Exposure Limits: Britain tries again. Ann Occup Hyg 2002;46: 435-437.
(3) Liljelind IE, Rappaport SM, J.O. Levin et al. Comparison of self- assessment and expert assessment of occupational exposure to chemicals. Scand J Work Environ Health 2001;27: 311-17.
(4) Friar JJ. The assessment of workplace exposure to substances hazardous to health. The EASE model. HSE, 1996.
(5) Bredendiek-Kämper S. Do EASE scenarios fir workplace reality? A validation study of the EASE model. Appl Occup Environ Hyg 2001;16: 182-187.
(6) Aitken R, Hughson R, Cherrie J. Validation of the EASE model in relation to dermal zinc exposures. Presented at the American Industrial Hygiene Conference and Exhibition, June 2-7, 2001, New Orleans, USA.
(7) Werner DB, Maxwell J, Thuman C. Where there is no doctor. The Hesperian Foundation, 1992, Berkeley, USA.
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Conflict of Interest:
None declared.
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Published on: 27 April 2016
Comments on article by Kromhout
- Michael Topping, Health Directorate
Dear Editor
I write in response to the article by Hans Kromhout[1] which sets out the case for exposure monitoring and proposes robust strategies for collecting data. He acknowledges that exposure monitoring may be expensive, but justifies it on the grounds that it is needed to ensure worker protection and data can be used for multiple purposes (hazard evaluation, control and epidemiology). All this ignores the...
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Dear Editor
I write in response to the article by Hans Kromhout[1] which sets out the case for exposure monitoring and proposes robust strategies for collecting data. He acknowledges that exposure monitoring may be expensive, but justifies it on the grounds that it is needed to ensure worker protection and data can be used for multiple purposes (hazard evaluation, control and epidemiology). All this ignores the variety of competences and numbers of firms who use chemicals in the workplace.
We agree that good quality exposure data is extremely valuable for assessing the effectiveness of control measures, studies on health effects related to use of specific substances and for long term epidemiological studies. Now that workers do not normally remain in one job all their working life and may be exposed to many chemicals in different industries, the lack of well validated exposure measurements is a concern. It will limit our ability in the future to carry out meaningful epidemiological studies.
In the UK we estimate that over 1.3 million firms are using chemicals. It is not realistic to suggest that all these firms should be carrying out the type of sampling regimes the article suggests. The costs would be astronomical and there is no capacity to collect, analyse and interpret all the samples that would be generated. Recognising this and that small firms needed help to apply the risk assessment requirements of the Control of Substances Hazardous to Health (COSHH) Regulations led HSE, in collaboration with industry and trade unions, to the develop COSHH Essentials.
COSHH Essentials is not intended to replace the collection of well validated exposure data, where that is justified, rather it is intended to help firms, particularly small and medium sized firms, properly control the chemicals they are using. Inevitably, a generic system like COSHH Essentials which groups chemicals has to err on the side of caution, but the controls recommended by COSHH Essentials were peer reviewed by an expert group established by the British Occupational Hygiene Society and have the support of the industry and trade unions. COSHH Essentials has been used now for over 3 years by many firms. We have not had complaints that the controls are over precautionary. Thus, we reject the implication in the article that using COSHH Essentials leads to "ill advised control measures will arguably be even more costly in the long run, a classic case of being "penny wise but pound foolish".
The article misrepresents the purpose of the expert system, Estimation and Assessment of Substances Exposure (EASE). This was developed to help meet the requirement under the Dangerous Substances Directive for a risk assessment on new substances. Since workplace exposure data cannot be collected on new substances prior to release to the market place, EASE was developed to provide an exposure estimate for use in risk assessment. It is entirely appropriate that this should be precautionary. It is not a weakness as the article implies. EASE is not intended as a tool to help employers control exposures in the workplace.
The aim of chemical control is the protection of employees' health. This is best achieved with a range of tools. EASE has a valuable contribution to make before substances are released into the market place, COSHH Essentials is proving to be a valuable and welcome tool for many small and medium sized firms, helping them to establish suitable controls. The recently launched electronic version will be of even greater help to many small firms. In other circumstances structured data collection is needed. These tools all have a valuable role to play. They should be viewed as complementary, not as alternatives in the way article suggests.
Reference
(1) Kromhout H. Design of measurement strategies for workplace exposuresOccup Environ Med 2002;59: 349-354.
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Conflict of Interest:
None declared.
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