The Big Chart of Federal Chemical Evaluations & Assessments

Today, I’m excited to share an infographic that I made, depicting all of the different chemical evaluations and assessments that various federal agencies (in the U.S.) conduct.

If you want to hear about the backstory & process for creating this, read on below.

Otherwise, here’s a link to a PDF version of the graphic. There are hyperlinks throughout, if you want to explore any of the information further. Yes, I know this is very detailed; it is meant to be digested by zooming around to different sections of the graphic.

I’ve tried to be as accurate as possible. But if you catch something that doesn’t look right, please let me know.

I hope this helps the environmental health community (and others who might be interested) better understand the review processes that are intended to keep us safe (unless/until politics get in the way…).

The backstory

In April, the Agency for Toxic Substances and Disease Control (ATSDR) released a draft ToxProfile for glyphosate. If you’ve been following this blog, you know that I’ve been paying a lot of attention to glyphosate lately (see some of my recent posts here and here). Given my interest in this topic, I decided to review the document and take the opportunity to prepare public comments.

[What are public comments, you might ask? Public comments are a way for the public to provide feedback during the federal rulemaking process. Under the Administrative Procedure Act (1946), whenever a federal agency develops a new regulation, they are required to solicit input from the public. (For more on the public comment process and how you can get involved, check out the Public Comment Project!)]

As I was reviewing ATSDR’s ToxProfile, I realized that I did not fully understand how this effort was distinct from EPA’s assessment of glyphosate. ATSDR and EPA are two separate federal agencies with different missions, so clearly these assessments served different purposes.

I soon realized that elucidating this distinction was just one part of a larger story. So, I decided to create a master chart to better understand all of the different types of reviews, evaluations, and assessments that different federal agencies conduct, the main purposes of these evaluations, and what other processes or regulations they might relate to.

The process

Some of the agency assessments were quite familiar to me or fairly well-explained online; for example, those that EPA is supposed to conduct under the recently reformed Toxic Substances Control Act. It was surprisingly hard to get clear information on other assessments and related agency activities, however (even for me, someone who is relatively well-versed in this field). Specifically, I found the online information for the Occupational Safety and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH), and the Consumer Product Safety Commission (CPSC) to be a bit confusing. I actually ended up calling several people at these agencies (using phone numbers listed online) to get clarifying information. (Thank you to those federal employees who picked up my cold calls and answered my questions!)

I started collecting this information in an excel chart, but this format is not very conducive to easy online reading or sharing. So, I decided to challenge myself to make an infographic, which I had never done before. I experimented with various online tools before settling on draw.io, which I also used to make the timeline in the glyphosate meta-analysis. I’ll spare you the details, but let’s just say, this took me a LONG time (sorry, dissertation, I’ll get back to you soon).

I imagine that I’ll continue to refine this over the next few months/years. If you see anything that looks wrong or have suggestions for improvement, let me know.

Lead exposure beyond Flint—protecting our nation’s workers

This commentary was published in the September 12, 2016 edition of Environmental Health News‘ Above the Fold. To view the original version, click here: http://www.environmentalhealthnews.org/ehs/news/2016/sept/commentary-lead-exposure-beyond-flint2014protecting-our-nation2019s-workers 

By Rachel Shaffer and Steven Gilbert
Environmental Health News

Lead poisoning returned to the national consciousness this year through the tragic events in Flint, Michigan, but drinking water is only one of many exposure routes. Because of outdated federal workplace safety standards, acute and chronic occupational lead exposure occurs all too often and can harm workers and their children, who may be exposed prenatally or through lead dust carried into the home. We need to protect workers and their families by updating federal workplace lead standards based on the latest scientific research.

The U.S. Occupational Safety and Health Administration (OSHA) regulates workplace lead exposure at the national level through two standards, the general industry standard and the construction industry standard. Both of these standards are severely outdated, based on information available in the 1970s instead of the latest scientific and medical evidence.

Image adapted from CDC/NIOSH

Thus, while OSHA’s mandate is to “assure so far as possible every working man and women in the Nation safe and healthful working conditions,” these goals have not been met for workplace lead exposure.

Under the existing regulations, workers can be exposed to levels of lead that result in 60 micrograms of lead per deciliter of blood before medical removal is required, and they can return to work after their blood lead levels are as high as 40 micrograms per deciliter.

As comparison, the Centers for Disease Control (CDC) defines blood lead levels above 5 micrograms per deciliter as “elevated” and has set a “Healthy People 2020” national public health goal that aims to reduce the proportion of workers with blood lead levels above 10 micrograms per deciliter.

Exposure to levels of lead much lower than what is allowable under OSHA’s current standards have been linked to high blood pressure, decreased kidney function, reproductive effects and neurological impairments.

In industries with high potential for lead exposure, such as construction, gun ranges, and battery reclaiming/manufacturing, not only are workers at risk, but their families may also be exposed inadvertently through take-home lead dust.

Children’s developing nervous systems are particularly vulnerable, and lead exposure can result in intellectual impairment. Stricter standards that require lower workplace lead levels and better personal protection will substantially reduce the dangers associated with take-home lead exposures.

In addition, since lead released from bones during pregnancy easily crosses the placenta, children born to lead-exposed workers are at risk for neurodevelopmental and other adverse health effects. Better standards will reduce potential fetal lead exposure in female workers of childbearing age.

Both California and Washington State are in the process of updating their own occupational lead standards. But, why should workers in only two states be privileged to improved health protections? OSHA standards, which cover all workers across the country, should also be strengthened to adequately protect workers and their families.

In the interim, though, enforcement of company compliance with existing federal regulations is also critical. A recent blog post from the U.S. Department of Labor described a case in which OSHA officials responded to worker complaints and cited a Wisconsin shipyard operator with 19 willful violations of the lead standard after detecting elevated blood lead levels in 75 percent of employees tested.

OSHA regulates workplace lead exposure at the national level through two standards. Both of these standards are severely outdated.The incident illustrates the importance of maintaining a well-funded OSHA ensuring it has the resources to monitor adherence to the standards. However, a draft bill for fiscal year 2017 suggests that OSHA’s budget would be cut significantly, which may prevent these enforcement activities and thus put workers at further risk.

We have the scientific and medical evidence that documents the harms of elevated blood lead levels, and we have the technology to reduce occupational lead exposure.

Now it is time to take action to put elevated workplace lead exposure behind us by rapidly adopting a standard that is aligned with CDC’s existing public health guidance, which classifies blood lead levels above 5 micrograms per deciliter as elevated.

We must strengthen OSHA standards for lead and provide sufficient support for the agency’s enforcement actions. The health of our workers – and their children – depends on it.

Outdated lead standards put Washington workers, families at risk

This op-ed originally appeared in the August 1, 2016 print edition of the Seattle Times. See here for the online posting: http://www.seattletimes.com/opinion/outdated-lead-standards-put-washington-workers-families-at-risk/ 

 

FGGM_Pb5Image credit:  https://phc.amedd.army.mil/topics/phcrspecific/north/Pages/IHD.aspx

By Rachel Shaffer and Steven Gilbert

THE tragedy in Flint, Mich., thrust lead contamination into the spotlight, and much attention has been focused rightly on the terrible consequences of childhood lead exposure.

Most people, however, are unaware that adults can also experience serious health effects from lead. As with many chemicals and hazards, workers are often more highly exposed than the general population. Examples of industries with high potential for lead exposure include construction and battery manufacturing. In these and other industries, not only are workers at elevated risk, but their families may also be exposed inadvertently through take-home lead dust.

In Washington state, there are two primary standards that regulate occupational exposure to lead: the “general industry lead standard” and the “lead in construction standard.” Unfortunately, both of these standards are severely outdated, based on information available in the 1970s instead of the latest scientific and medical evidence.

Under the existing inadequate standards, workers can be exposed to levels of lead that result in blood-lead levels up to six times higher than the Centers for Disease Control and Prevention’s maximum health goal for adults.

Moreover, levels of lead much lower than Washington state’s current standard have been linked to high blood pressure, decreased kidney function, reproductive effects and neurological impairments. Standards should change to reflect the latest public-health recommendations and scientific evidence.

To adequately protect workers and their families, blood-lead levels must be routinely monitored when there is any possibility of lead exposure, and individuals should be removed from their duties when their blood-lead levels are above the National Institute of Occupational Safety and Health’s reference level for adults.

We have the technology to drastically reduce occupational lead exposure. We need to give workers the safe workplaces they deserve.

The health benefits of updated occupational lead standards would extend beyond workers and would also protect their children and families.

Workers often inadvertently carry lead dust on their skin and clothing when they return home, which can cause lead poisoning among family members. Stricter standards that require lower workplace lead levels and better personal protection would substantially reduce take-home lead exposures.

Second, since lead easily crosses the placenta during pregnancy, children born to lead-exposed workers are at risk for neurodevelopmental and other adverse health effects. Better standards would reduce potential fetal lead exposure in female workers of childbearing age.

The state Department of Labor and Industries should move swiftly to update our existing outdated lead standards. Workers in this state should not be subject to the health risks of lead exposure. Nor should their children suffer the secondhand consequences of this well-known poison.

It’s time to take action and give our workers and their families the protection they deserve.

For additional information on the Washington State process to update the occupational lead standard, please visit: http://lni.wa.gov/Safety/Rules/WhatsNew/LeadSafety/default.asp