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Keys to effective third-party process safety audits.

The Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) regulation was promulgated in 1992. The U.S. Environmental Protection Agency's (EPA's) corresponding Risk Management Program (RMP) rule followed in 1996. Both programs include requirements for triennial compliance audits. Effective compliance audits are critical in identifying program weaknesses and ensuring the safety of facility personnel and the surrounding public. Large companies with corporate and facility health, safety, and environmental groups typically have the resources and experience to conduct audits internally, either through a corporate audit team or the sharing of personnel between multiple facilities. Small to medium sized businesses frequently do not have the expertise or the resources to perform compliance audits, and rely on third-party consultants to provide these services. This paper will discuss the observations of the authors in performing audits and working with PSM/RMP programs across a number of market sectors (e.g. chemical, petrochemical, pharmaceutical, food and beverage, water treatment), including effective practices, hurdles to successful implementation and execution of programs, and typical program shortcomings. The paper will also discuss steps to improve the audit process and increase effectiveness whether performed by a third party or internally.

Environmental Health↗

Performance assessments of nuclear waste repositories: a dialogue on their value and limitations.

Performance Assessment (PA) is the use of mathematical models to simulate the long-term behavior of engineered and geologic barriers in a nuclear waste repository; methods of uncertainty analysis are used to assess effects of parametric and conceptual uncertainties associated with the model system upon the uncertainty in outcomes of the simulation. PA is required by the U.S. Environmental Protection Agency as part of its certification process for geologic repositories for nuclear waste. This paper is a dialogue to explore the value and limitations of PA. Two "skeptics" acknowledge the utility of PA in organizing the scientific investigations that are necessary for confident siting and licensing of a repository; however, they maintain that the PA process, at least as it is currently implemented, is an essentially unscientific process with shortcomings that may provide results of limited use in evaluating actual effects on public health and safety. Conceptual uncertainties in a PA analysis can be so great that results can be confidently applied only over short time ranges, the antithesis of the purpose behind long-term, geologic disposal. Two "proponents" of PA agree that performance assessment is unscientific, but only in the sense that PA is an engineering analysis that uses existing scientific knowledge to support public policy decisions, rather than an investigation intended to increase fundamental knowledge of nature; PA has different goals and constraints than a typical scientific study. The "proponents" describe an ideal, six-step process for conducting generalized PA, here called probabilistic systems analysis (PSA); they note that virtually all scientific content of a PA is introduced during the model-building steps of a PSA; they contend that a PA based on simple but scientifically acceptable mathematical models can provide useful and objective input to regulatory decision makers. The value of the results of any PA must lie between these two views and will depend on the level of knowledge of the site, the degree to which models capture actual physical and chemical processes, the time over which extrapolations are made, and the proper evaluation of health risks attending implementation of the repository. The challenge is in evaluating whether the quality of the PA matches the needs of decision makers charged with protecting the health and safety of the public.

Geological Phenomena↗

Acute hazards to young children from residential pesticide exposures.

OBJECTIVES: This study assessed acute hazards to young children from pesticides toxic enough to require child-resistant packaging. METHODS: The names of pesticides meeting acute toxicity criteria were ascertained from the Environmental Protection Agency. Poison Control Center reports identified children younger than 6 years who were exposed to these pesticides. Toxicity category, medical outcome, sex, and age were examined. RESULTS: A higher proportion of children with exposure to the more toxic products had serious medical outcomes. Children 2 years and younger were the predominant age group exposed. CONCLUSIONS: Protective measures--substituting less lethal pesticides, reducing the concentration of the active ingredients, and improving packaging and storage--are recommended.

Age Distribution↗

An overview of human exposure modeling activities at the USEPA's National Exposure Research Laboratory.

The computational modeling of human exposure to environmental pollutants is one of the primary activities of the US Environmental Protection Agency (USEPA)s National Exposure Research Laboratory (NERL). Assessment of human exposures is a critical part of the overall risk assessment paradigm. In exposure assessment, we analyze the source-to-dose sequence of processes, in which pollutants are released from sources into the environment, where they may move through multiple environmental media, and to human receptors via multiple pathways. Exposure occurs at the environment-human interface, where pollutants are contacted in the course of human activities. Exposure may result in a dose, by which chemicals enter the body through multiple portals of entry, primarily inhalation, ingestion, and dermal absorption. Within the body, absorbed pollutants are distributed to, metabolized within, and eliminated from various organs and tissues, where they may cause toxicologic responses or adverse health effects. The NERL's modeling efforts are directed at improving our understanding of this sequence of processes, by characterizing the various factors influencing exposures and dose, and their associated variabilities and uncertainties. Modeling at the NERL is one of three essential programmatic elements, along with measurements and methods development. These are pursued interactively to advance our understanding of exposure-related processes. Exposure models are developed and run using the best currently available measurement data to simulate and predict population exposure and dose distributions, and to identify the most important factors and their variabilities and uncertainties. This knowledge is then used to guide the development of improved methods and measurements needed to obtain better data to improve the assessment and reduce critical uncertainties. These models and measurement results are tools that can be used in risk assessments and in risk management decisions in order to reduce harmful exposures. Current areas of the NERL's exposure modeling emphasis include: Pollutant concentrations in ambient (outdoor) air using the Third Generation Air Quality Modeling System's Community Multiscale Air Quality model (Models-3/CMAQ); Air flow and pollutant concentrations at local and microenvironmental scales using computational fluid dynamics (CFD); Human inhalation exposure to airborne particulate matter, air toxics, and multipathway exposure to pesticides, using the Stochastic Human Exposure and Dose Simulation (SHEDS) model; Human and ecological exposure and risk assessments of hazardous waste sites using Framework for Risk Analysis in Multimedia Environmental Systems--Multimedia, Multipathway, Multireceptor Risk Assessment (FRAMES-3MRA), one of many software programs available from the NERL's Center for Exposure Assessment Modeling (CEAM); Physiologically based pharmacokinetic (PBPK) modeling of pesticides and volatile organic compounds (VOCs) in the Exposure-Related Dose-Estimating Model (ERDEM). A brief historical overview of the NERL's evolution of human exposure models is presented, with examples of the present state-of-the-science represented by SHEDS and FRAMES-3MRA.

Air Pollutants↗

Consumer and market use of antibacterials at home.

In this increasingly complex, time-constrained world, consumers will continue to look for solutions that promise them peace of mind. A large component of this peace of mind is perceived as personal safety against infectious agents. Manufacturers have a responsibility to provide sound advice and to develop solutions to consumers' questions. Through working with leaders in the infection control field, as well as governmental organizations like the Centers for Disease Control and Prevention, the Food and Drug Administration and the Environmental Protection Agency, manufacturers can develop faster and more effective disinfectant and antimicrobial products. Targeted education programs are needed that clearly and effectively communicate proper infection control techniques and prudent use of antibacterial products to both the consumer and the health professional. Manufacturers should also work closely with the media to educate the public about the potential benefits and risks of their products. Finally manufacturers of household and personal cleaning products should help set guidelines for regulatory monitoring, including correct definition and use of common terms such as antibacterial, antimicrobial, antiviral and sanitization, as well as the extent of protection the consumer can expect from the product.

Centers for Disease Control and Prevention, U.S.↗

Pesticide exports from U.S. ports, 1997-2000.

U.S. Customs records reveal that 3.2 billion pounds of pesticide products were exported in 1997-2000, an average rate of 45 tons per hour. Nearly 65 million pounds of the exported pesticides were either forbidden or severely restricted in the United States; however, no banned pesticide export was recorded for the year 2000. 2.2 million pounds of pesticides regulated under a treaty on persistent organic pollutants (POPs) were exported between 1997 and 1999, with no such export in 2000. Exports of pesticides subject to the prior informed consent (PIC) treaty decreased 97% from the 1997 total of nearly 3 million pounds. Thus, international efforts to reduce the trade in hazardous pesticides may be bearing fruit. However, they are balanced by high rates of export of pesticides designated "extremely hazardous" by the WHO (89 million pounds), pesticides associated with cancer (170 million pounds), and pesticides associated with endocrine disrupting effects (368 million pounds), mostly to developing countries. These findings point in two directions: first, progress is possible, and second, the focus of international efforts should be expanded. From public health and environmental protection perspectives, exports of hazardous pesticides remain unacceptably high.

Animals↗

Biological effects of low-level exposures: a perspective from U.S. EPA scientists.

Biological effects of low-level exposures (BELLE) may be very important in characterizing the potential health risks of environmental pollutants. Before some features of BELLE, such as effects that may be modulated by adaptive or defense mechanisms, can be taken into greater consideration in U.S. Environmental Protection Agency risk assessments, however adequate information on a toxicant's mode of action and answers to other questions are needed.

Adaptation, Physiological↗

Acute health reference values: overview, perspective, and current forecast of needs.

A number of organizations have developed acute inhalation health reference values, each with (1) a specific purpose, (2) populations to protect, (3) exposure scenarios (accidental releases, workplace, routine excursions of ambient levels), and (4) severity of adverse health effects considered in their development. The first section of this article reviews the existing values from different organizations and describes their purposes and method of development. The second part of the article provides a comparative review of how the values were derived, the critical endpoints considered for each value, the populations being protected by each value, and the potential for use outside of their intended purpose (e.g., Homeland Security, regulatory analysis, etc.). Additionally, an analysis of the acute inhalation reference values that was developed in support of the Office of Air and Radiation's residual risk assessment for hazardous air pollutants is presented and reviewed. The third and final part of the article focuses on the efforts of the U.S. Environmental Protection Agency (EPA) to develop a set of less-than-lifetime reference values, along with a discussion of how that effort fits with the existing sets of values described in the prior sections.

Air Pollutants↗

The benefits and costs of reducing emissions from the electricity sector.

Recent federal policy proposals to reduce emissions of sulfur dioxide (SO(2)), nitrogen oxides (NO(x)), and mercury from the US electricity sector promise important improvements in air quality and reductions in acid deposition. The cost of achieving these reductions depends on the form and stringency of the regulation. In this research, we analyze the economic benefits and costs of the US Environmental Protection Agency's (EPA's) Clean Air Interstate Rule (CAIR) as characterized in the supplemental rule proposed in June 2004, and the Clean Air Mercury Rule (CAMR) as proposed in February 2004. The assessment integrates a model of the electricity sector, two models of atmospheric transport of air pollutants, and a model of environmental and public health endpoints affected by pollution. We model explicitly the emissions of SO(2), NO(x), mercury and carbon dioxide (CO(2)) and the effects of changes in emissions of SO(2) and NO(x) on environmental and public health. The manner in which mercury emissions are regulated will have important implications not only for the cost of the regulation, but also for emission levels for SO(2) and NO(x) and where those emissions are located. We find the economic benefits of CAIR and CAMR are far greater than the costs. Recent estimates of benefits of reductions in mercury and acidification indicate that our model captures the lion's share of quantifiable benefits. We also find that the EPA would have been justified on economic grounds in pursuing additional SO(2) emissions reductions beyond the requirements of CAIR.

Air Pollution↗

What industrial hygienists should know about TSCA.

Direct participation of industrial hygiene personnel in planning and implementing compliance with several pertinent sections of the Toxic Substances Control Act (TSCA) is warranted. TSCA is administered by the Environmental Protection Agency and there is a variety of areas in which industrial hygiene input is and will be required. Major sections of TSCA which require industrial hygiene participation include Testing, Premanufacture Notices (PMNs), Regulation of Hazardous Chemicals, and Reporting and Recordkeeping. The industrial hygiene input requires interaction with other groups such as Toxicology, Environmental, Government Regulations, Legal, Medical, Research and Development, Marketing and Manufacturing in order to provide a comprehensive response to and compliance with current and anticipated TSCA rules.

Chemical Industry↗

FIFRA Subdivision F testing Guidelines: are these tests adequate to detect potential hormonal activity for crop protection chemicals? Federal Insecticide, Fungicide, and Rodenticide Act.

Recently, a major topic of discussion has been the impact of synthetic chemicals that possess the capacity to alter hormonal activity, the so-called "endocrine modulators," with potentially the capacity to alter the reproductive capability of humans. Particularly, various synthetic pesticides and industrial chemicals that persist in the environment and/or bioaccumulate have been implicated. Further, it has been alleged that the standard tests for pesticide registration as required by the U.S. Environmental Protection Agency (EPA) and other regulatory agencies may be inadequate to detect endocrine modulating effects. To address these shortcomings, it has been proposed that very specific tests for estrogen receptor binding, or in vitro cell response to chemicals, be used to identify potential endocrine modulators. However, such approaches have certain flaws that limit their application as screens. First, very specific tests, like receptor binding, evaluate only a single chemical event per test. Such tests do not measure toxicity or biological response. Isolated systems are very important for studying mechanisms of action or structure activity relationships, but can only provide a preliminary screen for a single mechanism of toxicity. Isolated systems can not be used to regulate a chemical without additional information. Second, they fail to test many other parts of the neuroendocrine control of the reproductive system. Testing for adverse effects in highly specific in vitro systems failed to replace whole-animal models in carcinogenesis and will also fail in reproductive toxicology because this system is too complicated for such as in vitro approach to be accurately predictive. Advanced tests, such as the EPA multigeneration study, are more effective, and reliable means for evaluation than any specific and narrowly focused screening tests. Experience has shown that a better approach to testing chemicals is to evaluate their effects on the whole animal. When one part of the system is adversely affected, various processes may be indirectly affected and can be detected in the animal model. For example, a modulation of testosterone synthesis could lead to (1) altered accessory sex organ morphology, size, and function; (2) decreased sperm counts; and (3) even decreased fertility. These and many other effects would be noted in toxicity studies that are already required for the registration of crop protection chemicals. The developmental and reproductive toxicity guidelines were recently reviewed in a hearing that included the representatives from the EPA, the public, and the Scientific Advisory Panel. The EPA kept the basic study design the same, but added a few new endpoints to further assess chemical-induced effects on reproductive development and function. The review presented herein concentrates on the required Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) testing for pesticides, and demonstrates how the massive arrays of sensitive endocrine endpoints that are delineated in FIFRA Subdivision F have been successfully used to detect both weak and potent hormonally modulating chemicals. For example, (1) diethyl-stilbestrol (DES), which is a potent synthetic therapeutic estrogen, (2) DDT, which is weakly estrogenic but persistent and bioaccumulating, and (3) dioxins, which have antiestrogenic properties, were all found as being hormonally active in tests similar or identical to FIFRA tests. All food-use pesticides have been evaluated using a comprehensive multigeneration reproduction test. Hence, the FIFRA testing procedures have been demonstrated to identify endocrine modulators of sufficient potency to represent a concern to human health.

Animals↗

Superfund and one community program.

The U.S. Environmental Protection Agency--Region II conducted a pilot program in risk communication and notification of hazardous waste information at a Superfund site in Toms River, New Jersey. The program was designed to assess the levels of awareness and concern among local citizens and to provide accurate information about health risks associated with potential exposure to environmental contaminants. The purpose of this program was to develop linkages among the community; local, state, and federal governments; industry; health professionals; and educators in dealing with environmental problems. A Community Leaders Network was formed and became actively involved in the program. Following a community needs assessment for risk information, a series of fact sheets was developed, pretested, disseminated, and evaluated. The analysis of the program highlights the important lesson of being able to respond to the specific changing dynamics of the community and offers guidelines useful for risk communication in many communities.

Chemical Industry↗

The new standard environmental inventory questionnaire for estimation of indoor concentrations.

Several investigators have developed indoor air quality questionnaires for use in field studies. The approach used in many of them have numerous features in common, but most of them are unique in their content (wording, format, item selection). It is thought that indoor air quality research could be greatly advanced if the primary or fundamental questions and instruments could be consolidated. The use of a basic set of "standard" questions would permit intercomparison of results from different research studies. It is generally agreed that environmental inventory questionnaires (EIQ) help to classify, at least in screening, relative concentration estimates, which precede exposure estimation. Thus, such instruments are not equivalent to monitoring for exposure assessment. However, data linkage and mega data bases are important for some comparative analyses of exposure assessment and exposure-response relationships. Standard instruments such as the EIQ are useful as a screening device to precede other tests to allow identification of potentially high exposure situations. They can also amplify information from other tests. General usage of standard questionnaires and protocols can lead to cumulative improvements in data collection, specificity and effectiveness. This has been the rationale for the present efforts by investigators to form a standardized environmental inventory questionnaire, under the auspices of the U.S. Environmental Protection Agency (EPA), Gas Research Institute (GRI), and Electric Power Research Institute (EPRI).

Air↗

A review of scientific literature examining the mining history, geology, mineralogy, and amphibole asbestos health effects of the Rainy Creek igneous complex, Libby, Montana, USA.

This article reviews the past 90 yr of scientific research directed on multiple aspects of the unique geology and environmental health issues surrounding the vermiculite deposit found at Libby, MT. Hydrothermal alteration and extensive weathering of the ultramafic units resulted in the formation of a rich deposit of vermiculite that was mined for 67 yr and used in numerous consumer products in its expanded form. Later intrusions of alkaline units caused hydrothermal alteration of the pyroxenes, resulting in formation of amphiboles. Some of these amphiboles occur in the asbestiform habit and have been associated with pulmonary disease in former miners and mill workers. Identification of these amphibole asbestos minerals has received little attention in the past, but recent work shows that the majority of the amphibole mineral species present may not be any of the amphibole species currently regulated by government agencies. Epidemiological studies on former miners have, nevertheless, shown that the amphibole asbestos from the Rainy Creek igneous complex is harmful; also, a recent study by the Agency for Toxic Substances and Disease Registry shows that residents of Libby who had not been employed in the vermiculite mining or milling operations also appear to have developed asbestos-related pulmonary diseases at a higher rate than the general public elsewhere. Since November 1999, the U.S. Environmental Protection Agency has been involved in the cleanup of asbestos-contaminated sites in and around Libby associated with the mining and processing of vermiculite.

Aluminum Silicates↗

A critical evaluation of the use of mutagenesis, carcinogenesis, and tumor promotion data in a cancer risk assessment of 2,3,7,8-tetrachlorodibenzo-p-dioxin.

Regulatory agencies in the Western Hemisphere are currently assessing the potential human health risks of environmental contamination by 2,3,7,8 tetrachlorodibenzo-p-dioxin (TCDD). Some U.S. agencies such as the Environmental Protection Agency (EPA) and Centers for Disease Control (CDC) have assumed that TCDD behaves as a tumor initiator in animals and have used linear low-dose mathematical extrapolation models for estimating any human risk. In contrast, the Ontario Ministry of the Environment, the State Institute of National Health of The Netherlands, and the Federal Environmental Agency of the Federal Republic of Germany have concluded that TCDD does not have initiator activity; these agencies have advocated a risk extrapolation approach which applies a safety factor to a no-observable-effect level. Estimations of the potential risk obtained by these two approaches can differ by three to four orders of magnitude and have a major impact on the allocation of resources within the affected countries. This paper critically reviews the TCDD bacterial, animal, and human data on mutagenesis, carcinogenesis, and tumor promotion and concludes that the scientific evidence does not support risk estimations which are based on TCDD as a tumor initiator. Rather, the animal data overwhelmingly support TCDD as a tumor promoter. Risk estimations which incorporate tumor promotion activity more accurately reflect the scientific understanding of TCDD's mechanism of action and provide better estimates of its risk.

Animals↗

Chlorpyrifos: an unwelcome pesticide in our homes.

Chlorpyrifos is an extensively used organophosphate insecticide having many urban and agricultural crop pest control uses. Studies conducted in indoor environments after termiticide, crack-and-crevice, broadcast, or fogger applications have shown that chlorpyrifos exposure can occur via inhalation of residual air concentrations, dermal or oral exposure from residues on floors and carpets, children toys, food, and dust. Not long ago the weight of scientific evidence supported safe indoor use, but recent studies support the possibility that when pregnant female rats are given the pesticide, chlorpyrifos causes brain damage in fetal rats. Moreover, the exposure of young rats to chlorpyrifos impairs early nervous system development. After finding that chlorpyrifos is an exposure risk especially to children, in June 2000 the United States Environmental Protection Agency and manufacturers agreed to voluntary measures that will reduce the exposure of children to chlorpyrifos-containing products. This action implies a search for less harmful new products to replace it and/or safer ways to control pests through basic hygiene. Whichever pest control method is selected, one should keep in mind that preventing environmental pesticide exposure in children is always better than treating the resulting disease.

Air Pollution, Indoor↗

Health issues in the Clean Air Act.

Major conclusions and recommendations of the National Commission on Air Quality on issues of health in the Clean Air Act are presented. The issues revolve mainly about the standard setting processes for ubiquitous pollutants, controlled through ambient air quality standards (Section 109), and for hazardous pollutants controlled through emission standards (Section 112). The conceptual difficulties inherent in the terms "adequate margin of safety" (Section 109) and "ample margin of safety" (Section 112) are discussed. The Clean Air Science Advisory Committee is widely viewed as having a salutary effect on standard setting. The need for maintaining strong research capabilities within the Environmental Protection Agency that are reasonably buffered against sudden disruptive events is emphasized. Mechanisms for achieving this goal through special congressional appropriations are considered.

Air Pollution↗

Sources of hazardous waste in hospitals.

Knowing which hospital wastes the Environmental Protection Agency considers hazardous and which are considered nonhazardous can mean big dollar savings in proper handling and disposal costs.

Materials Management, Hospital↗