It’s been good to see OSHA adding more Gulf sampling data to its website, but the presentation of the information there isn’t quite as detailed as we were expecting to see. We asked an industrial hygienist colleague for a reaction to the web pages, and got an in-depth response. Here are one industrial hygienist’s recommendations for how OSHA can make its online sampling data more useful:
After reviewing OSHA’s “Keeping Workers Safe During Oil Spill Response and Cleanup Operations” series of websites, I recommend that OSHA improve the information technology capacity of the sites and add additional quantitative and qualitative industrial hygiene data to ensure all members of the public, from professional technicians to concerned beach goers, can quickly determine if exposures exceed occupational exposure limits.
Change the “Lab Analysis Results” page title to “Integrated Sampling and Lab Analysis Results” and provide an explanation of what integrated sampling is in context to direct read (also referred to as instantaneous read) sampling. OSHA compliance officers will know the difference between these common industrial hygiene sampling types; the difference should be provided either in the opening paragraph to these pages or by using embedded hyperlinks on key terms.
In addition to the data already provided, the website for “Integrated Sampling and Lab Analysis Results” also should include:
1) the type of sample collected: area or personal (not “person” as it reads now));
2) an embedded hyperlink to the sampling method information: the information provided on the “Emergency Response Initial Sampling Strategy” site (a sister site included in the Keeping Workers Safe During Oil Spill Response and Cleanup Operations websites) is good, but it would be better if it linked directly with the sampling results;
3) clarification for non detects (NDs): if the analyte was not detected during laboratory analyses, then the limit of detection should be listed;
4) an embedded hyperlink that defines the units for each sampling result;
5) a column and or embedded hyperlink to a listing of the occupational exposure limits: this information is provided on the “Emergency Response Initial Sampling Strategy” site (a sister site included in the Keeping Workers Safe During Oil Spill Response and Cleanup Operations websites) but that’s “too far away” to be useful when reviewing the sampling results;
6) a column that provides a definitive qualifier (yes/no or >) as to whether the exposure monitoring result exceeds an established, stringent occupational exposure limit. Whether they elect to use OSHA, ACGIH, NIOSH, or AIHA (WEEL, not WHEEL as stated on the website) limits for comparison will be up to OSHA, but I would recommend using the most protective. Keep in mind that NDs can exceed occupational exposure limits.
In addition to the data already provided, the website for “Direct Reading Results by Site” also should include:
1) a job title, job description, work activities, and/or area where sample was collected for each data point: the two column headers “Job Description” and “Location Remarks” already in the data tables are okay, however in many cases the fields are left blank. There should not be any blanks in the data tables;
2) “parameter/substance being sampled” as a column header instead of “substance,” e.g., LEL/hydrocarbons or PID/VOCs, and an embedded hyperlink to ensure each of these terms is defined and or explained;
3) information on the direct reading equipment being employed, including the meter make and model and field/factory calibration information this information can be provided in a hyperlink to another page;
4) units for each result and an embedded hyperlink that defines the unit;
5) a column that provides a definitive qualifier (yes/no or >) as to whether the direct read result exceeds an established, stringent occupational exposure limit. Whether they elect to use OSHA, ACGIH, NIOSH, or AIHA limits will be up to them, but I would recommend using the most protective. Even NDs can exceed occupational exposure limits.
I am hopeful that the OSHA officers’ field notes are more detailed than the data presented on these websites; I will trust that the OSHA officers are experienced field technicians who take good field notes, use checklists, and/or otherwise document exposure monitoring details. I am also hopeful that an IT professional can work with the IH professionals to improve these websites such that they provide an abundance of information that is accessible via hyperlinks or pop up text or other “creative communication” format.
The disastrous oil spill is an opportunity for OSHA to demonstrate that it can easily and with a high level of transparency collect and report occupational exposure monitoring results. This is not a new science.
As our IH colleague says, OSHA probably has the kind of detailed information that public health professionals expect to see when they look at sampling data. Investing a few more resources to put more of that information onto the website could pay big dividends by strengthening trust and confidence in the agency.