Posted by Melanie Trottman reported in the Wall Street Journal last week that US Representatives James Oberstar and Jerrold Nadler have demanded that Gulf response and recovery workers be provided with respirators (among other protective equipment), but OSHA doesn’t think respirators should be required:
David Michaels, assistant secretary for the Department of Labor’s OSHA, said in an interview Thursday that based on test results so far, cleanup workers are receiving “minimal” exposure to airborne toxins. OSHA will require that BP provide certain protective clothing, but not respirators.
The “based on test results so far” phrase is key.
We know oil contains toxic compounds (see Deborah Blum’s helpful explanations on oil and oil-dispersant mixtures at Speakeasy Science for details), but we don’t know how much of its constituent chemicals workers are likely to breathe in. Given that we have thousands of workers doing a variety of jobs across a multi-state area, appropriate monitoring is a challenge. Workers handling controlled burns will get different exposures from those laying booms or cleaning beaches.
Elizabeth reported here yesterday about the air monitoring results that OSHA has just released; they cover sampling performed at two beach cleanup locations and on board one vessel, and OSHA’s conclusion was that data do not indicate workers “are being exposed to hazardous levels of substances or agents.”
Previously, OSHA stated that its recommendations were based on BP data, and they may still be using BP data in addition to their own. Presumably, OSHA can get the raw data from BP and its contractors and judge whether the sampling protocols are adequate. Member of the public have to content themselves with visiting OSHA’s website and accessing a BP summary report, which doesn’t provide details on where and how air samples have been taken. The report states that “approximately 400 personal samples have been taken” and that personal monitoring is going on in three work areas. The BP report shows the number of benzene and hydrocarbon samples with results falling into different ranges, with none of the benzene samples falling below the action limit of 0.5ppm and none of the hydrocarbon samples reaching the VOC action limit of 100ppm. It does not show results for other substances.
What needs to be happening in the Gulf is a large-scale exposure assessment of the individuals involved in the hazardous material clean-up efforts. Exposure assessments identify the chemical, biological, and physical agents present in a work environment and evaluate the extent to which workers in that environment are exposed to those agents. It’s important to consider different routes of exposure, since some agents are inhaled, others penetrate the skin, and some do both.
Ideally, those conducting exposure assessments consult with workers to identify the many different tasks they perform, the possible agents of concern, and which tasks pose the greatest potential risk for workers’ exposure to the hazards in the work environment. A thorough exposure assessment will strive to evaluate workers’ exposures during typical work-shift circumstances. Assessments can focus on the workers who are expected to have the greatest potential for exposure; this can give the people relying on the results greater confidence that workers in other settings have less exposure to the agents being assessed. It’s also helpful if exposure assessments can consider agents that may not yet have been identified as having adverse health effects, but that might turn out to play a role in health outcomes upon further analysis.
Difficulties in the Gulf
I do want to note that some hazards of the oil response work are relatively straightforward – things like heat illness and unintentional injury – and the WSJ article reports that OSHA is paying attention to those. But then there are several ways the situation in the Gulf makes it hard to follow good occupational health procedures.
If exposure assessments show that workers performing certain tasks are exposed to measurable levels of toxic substances, precautions must be taken. In many workplaces, employers can eliminate a harmful substance from the work environment, substitute a less-toxic alternative, or use engineering controls to reduce exposures. That’s not so easy in the Gulf, since the geyser of oil is hard to control and oil cleanup workers have to handle oil as part of their jobs.
When exposures can’t be completely eliminated, the goal is to get them within safe levels – but we have too little information about “safe” levels of many of the substances present (which include oil in various states, dispersants, smoke from controlled burns, UV, etc) either individually or in combination. OSHA has admitted for decades that its exposure limits for toxic agents are scandalously out of date, so we can’t rely on OSHA permissible exposure limits to tell us whether workers’ exposures to these compounds are likely to harm their health. A preacautionary approach suggests we should consider the exposures harmful in the absence of evidence to the contrary.
If employers have done all they can to eliminate or control harmful exposures but workers are still exposed to a hazard, personal protective equipment like respirators is a logical next step. Occupational health advocates are often reluctant to recommend respirators, though, because they’re not a great solution. They’re uncomfortable to wear – especially in hot, humid conditions like the Gulf in summer; they impede communication; and they can even be hazardous to people with respiratory or other health problems.
If, despite their drawbacks, respirators turn out to be the best option for some groups of Gulf cleanup workers, BP will need to provide the workers not with just any old respirator, but with one approved for use with the substances they’re encountering. The N95 respirators that were widely used during the swine flu pandemic aren’t approved for use with oil. Respirators also need to be properly fitted to make sure they work as designed, and people with facial hair can’t get a proper fit.
One possibility is to give workers extensive training on the different exposures, what we know and don’t know about health risks, how to use respirators and the pros and cons of their use – and then let individual workers decide whether to wear them on or not. If the respirators aren’t required, though, some workers who consider respirators their best option might forgo wearing them anyway if their co-workers are going without.
Based on some comments I’ve heard and seen, I think some people believe that supplying and using respirators in the Gulf is the simple, obvious, and easy thing to do. Respirators may be necessary for some Gulf workers, but they’re not a panacea. OSHA should be working to get the best exposure data they can for different workers in different locations, and using it to make exposure-reduction recommendations that involve a variety of tools from the occupational health toolbox.
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March 18, 2011