4.1 Applicability of IH Competencies to PS Activities
Elsewhere in this chapter, it is described that PS has certain basic activities which are rooted in regulatory requirements:
hazard assessment.
hazard communication.
risk management.
product development.
These activities, moreover, define the minimum standard for any PS program to be compliant or effective. Let us examine each of these basic PS functions against the IH competencies we have defined which are typically exhibited by professional IHs:
1 Hazard Assessment: Virtually all of the IH competencies contribute to this activity, especially nos. 1, 3, 4, and 5. The “Evaluation” part of the basic IH process is indeed hazard assessment and includes the concepts of hazard measurement, exposure estimation, and control banding. For PS purposes, exposure assessments often need to be made for products used in poorly defined applications and across an entire life span through disposal. In other words, it is necessary to estimate and understand exposure potential in unseen workplaces and use scenarios. The training and experiences of an IH are second to none for performing this PS activity. Additionally, as the hazard assessment focus oscillates during a product life cycle from lab to pilot to manufacturing to sales to customers, the IH is the best suited to integrate all the pieces of the chain to minimize information gaps.
2 Hazard communication: Hazard communication comes in two varieties as a required step in the process of hazard assessment, or by communicating hazards which have been assessed by others. In the first case, an IH almost inescapably has competency in the hazard assessment process including the communication of results to appropriate parties in appropriate ways. In case no. 2, which represents a typical process of providing MSDSs for products to customers, the trained/experienced IH has the advantage of recognizing the quality of information contained in data sheets. Additionally, an IH can recognize when the information intended for customers' needs to be used in other stages of product development, that is, research or manufacturing. As with hazard assessment, IH competencies nos. 1, 3, 4, and 5 are all particularly relevant.
3 Risk Assessment/Risk Management (RA/RM): RA/RM is a two‐step process which first combines hazard assessment with relevant toxicology to create risk assessment, and then applies control recommendations to mitigate the risk. It is, in essence, the “Control” stage of the classic IH process. While RA/RM has often been considered the milieu of the toxicologist or the engineer (depending on the circumstances), the competencies of the IH are uniquely suited to this PS activity. In this case, all the listed IH competencies come to bear, especially no. 3 which is specific to RA/RM. The toxicological/health effects data required to do RA/RM can be learned or leveraged by the IH. Once again, a trained IH has the advantage of looking across the integrated life cycle of a product and recognize strengths versus gaps in the quality of the information and the completeness of the hazard/risk communications.
4 Product Development: During new product development activities, numerous specific regulatory notifications are required. These are primarily under the jurisdiction of the EPA TSCA in the United States, and similar hazardous substance control agencies in many countries. There are global shipping requirements for the export, transport, and import of hazardous materials. Additionally, there are hazardous material inventory reporting requirements to comply with.
All of these tasks involve both technical and logistical product information. A key IH competency here is no. 2, the ability to navigate a virtual regulatory gauntlet. The technical data required for this activity is generally contributed by research, manufacturing, IH, toxicology (especially renew chemical testing), and sales/marketing. Overall compliance of such an interdisciplinary effort is only achieved by a comprehensive PS regulatory management system. The trained IH, with technical, field, process, and multidisciplinary experience is a good choice to lead this effort.
Excerpts from an actual job description for a PS professional staff position with a selected global specialty chemical company are found below.
The following job description excerpts describe the salient responsibilities, skills, relationships, and qualifications sought by a specialty chemical company to fill a professional PS position (content omitted was company‐specific information/relationships).
Importantly, the reader should note the job expectations which would (or easily could) be met by a high percentage of IHs. This current, real job description is typical of many, and reinforces the practical applicability of industrial hygiene competencies to PS practice.
Key Responsibilities, Skills, and Relationships
Communicate PS information to customers.
Author MSDSs for company products.
Becoming the “power user” for e‐MSDS systems.
Assist in the PS part of new product development.
Communicate appropriately at all levels to respective business units.
Qualifications
Strong written and verbal skills.
Baccalaureate degree in Chemistry, Environmental Science, or Industrial Hygiene.
Zero to three years experience.
Demonstrated skill to work effectively in a multidisciplinary team.
Willingness to take the initiative on projects with a minimum degree of supervision.
Project management experience considered a plus.
Familiarity with global new chemical regulations, MSDSs, and transportation regulations considered a plus.
Strong organic chemistry background considered a plus.
5 SUMMARY AND CONCLUSIONS
PS is a significant regulatory and health protection activity required for all commercial entities, which create, market, transport, import, or dispose of hazardous materials. The number and complexity of PS‐related regulations continues to grow globally with the implementation of REACH, GHS, expanded EPA inventory reporting requirements, and a growing list of countries related regulations.
Perhaps more significantly, social expectations for freedom of information and a sharp reduction of “trade‐secret” information protection means that business sustainability will depend increasingly on transparent PS programs. The overall number of occupational health professionals who will need to practice PS is consequently likely to grow.
IH professionals practice health protection and regulatory compliance in a framework which is different, yet closely related to PS. This chapter has attempted to illustrate that many of the technical and experiential competencies required for PS are commonly possessed by IHs. Assuming that is true in at least a reasonable percentage of cases, it means that many IHs could have opportunities by expanding their awareness PS. These opportunities are of (at least) two varieties
1 Many, if not all, IHs would sharpen their health protection skills by studying the activities of PS. Within the practice of PS there are sophisticated models for RA/RM and for multitargeted hazard communication. The product‐based life cycle approach to health protection can help the IH do better in a facility‐based model. Additionally, depending on the job environment, the IH may be able to directly integrate with the PS function of an organization if he/she is aware of the needs. Examples throughout this chapter speak to the advantage of IHs being learned in PS and vice versa.
2 Many IHs would have the option to evolve their practice partly or wholly into that of PS, if they wished to. The competencies to perform PS activities are generally already present and the learning curve is rapid. There are examples cited in this chapter where this has happened, and continues to happen