Advanced Industrial Hygiene

  

Part I: Introduce yourself to your classmates with your name, location, current employment, and future goals.

Part II: Only Occupational Safety and Health Administration (OSHA) standards are legally enforceable in facilities that are regulated by OSHA. However, many of the OSHA standards are severely outdated and can be based on scientific research from the 1970s or earlier. Other organizations, like the American Conference of Governmental Industrial Hygienists (ACGIH), publish guidelines that are based on more recent scientific research. What are your thoughts on whether a facility should only worry about complying with the OSHA regulations or go beyond compliance and use the stricter requirements of either NIOSH, ACGIH or other industry-wide guidelines?
(Note: This is a “trick” question. This will require that you weigh legal requirements against what is best for workers. Also, it will force you to think about the various reasons why an OEL might be more strict. Please don’t assume that for an IH professional, simply meeting the regulatory requirement is sufficient as this destroys the ethical basis for being an OHS professional) . Please contact me if you feel differently.  Please include any personal experiences you might have.
Please add references as applicable as we are looking for your “informed” opinion. See my announcement on “expectations” for the course.
Please include the name of the person or question to which you are replying in the subject line. For example, “Tom’s response to Susan’s comment.”  ALSO PLEASE REPLY TO ANOTHER STUDENTS COMMENT BELOW 
SAMANTHA:
My name is Samantha Frazier, I am in Northeast Arkansas and travel to the boot heel of Missouri every day for work. I am currently working as a safety director for a rather small (75 employees) roofing company with two locations on in Missouri and the other in Tennessee. I am hoping to be with this company for a while, I just started 4 months ago, but I hope to finish my master’s in occupational health and safety and get my GSP, then from there get my CSP.
At my first safety job my supervisor told me to look at OSHA standards as minimum legal requirements. They are there as a baseline for companies to build on and give a basic health and safety standard. Nowhere does OSHA say that you cannot go above and beyond, if anything they encourage companies to use NFPA, ANSI, NIOSH, ISO and others to provide best practices. OSHA does try to update based on outside standards by using their ability to Incorporate by reference. In OSHA 1926.6 there are multiple standards from non-government organizations. Another aspect to look at when examining whether following the guidelines site by OSHA is enough is worker’s compensation. If case law shows that not following a certain regulation could result in a negative outcome for the company then that regulation should be followed. According to Industrial Hygiene Staying safe in the oil field by Isaac Stone Simonelli  “When a company fails to comply with safety standards and there is a resulting injury, it can lead to expensive workers’ compensation lawsuits and damage a company’s reputation” (2019). These are great reasons to pay attention and follow organizations standards other than OSHA where applicable, but they are not the main reason. As a Safety professional your #1 priority is not meeting OSHA standards, it is keeping your employees safe. Sometimes that means you must go above OSHA standards, sometimes that means being creative to make sure employees are not getting hurt. Outside organizations do studies and research and then just publish their findings and update their regulations they do not have to wait on government approval, which can take years.
I hear on a weekly basis that most safety is common sense and in some cases that is true. What most of my employees do not think about is the unknowns, not all injuries and illness happen immediately some have a delayed onset. That is why airing on the side of caution and being strict with exposure limits is important.
Simonelli, I. S. (2019, December 1). Industrial Hygiene: Staying safe in the oil field. Alaska Business Monthly, 35(12).

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