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LETTERS
The opinions expressed in letters to the editor are those of the authors and do not necessarily reflect the views of AIHA® or The Synergist®. Letters are published at the discretion of the editor and may be edited for clarity. Send letters to synergist@aiha.org.
Should AIHA Support a Ban on Any Hazardous Material?
In January 2016, the Social Concerns and International Affairs Committees requested the AIHA Board of Directors to support an international ban on lead in paint. The Board affirmed its long-standing position that it would not support banning or endorsing the manufacture, sale, import, export or use of any product. Below is a letter from members of the Social Concerns Committee about the Board’s position, followed by a response from the Board.

DEAR EDITOR: Industrial hygienists are trained to make the workplace and community safer. We go into a workplace, assess the situation and make recommendations for controls to prevent occupational illnesses. Normally, these recommendations follow the hierarchy of controls where substitution with a safer product or elimination of the product is the first consideration. As you move down the hierarchy, the risk of exposure increases as the controls become less reliable. 
A toxic substance has some inherent risk based on its toxic properties. This toxicity estimate is coupled with exposure scenarios to estimate the actual risk. Certain substances are extremely toxic (for example, beryllium) but are used in small quantities, under highly controlled conditions. Other substances, like silica, are widely used and relatively uncontrolled. Some substances are only used in industrial settings while others are also used by consumers who are much less sophisticated in their use and more likely to be overexposed. While a hygienist may be able to control exposures under ideal conditions, we have to accept that most circumstances will be far from ideal and must take that into consideration when making recommendations. 
Are some substances so toxic that safe use will be difficult to assure and, where safer substitutes exist, the substances should be banned? Asbestos and lead paint are two examples. Asbestos is known to cause about 10,000 occupational fatalities a year in the U.S. alone. Lead exposures are responsible for 675,000 deaths globally. The toxicity of lead has been increasing as we learn more about it, and its production is also increasing. The public is at risk from exposure to lead paint, lead-contaminated drinking water and lead in soil and house dust. 
The cost of a product and its use does not often consider the life-cycle costs of removal, replacement of lead pipes, treatment of water in perpetuity or lead paint hazard control. Asbestos and lead removal can be enormously expensive, and the costs of treating asbestos and lead-related diseases are astronomical. The cost of lead poisoning in childhood is estimated to be at least $50.9 billion. The AIHA emphasis on product stewardship should require us as safety and health professionals to consider the life-cycle costs. In these cases, from a preventive and public health perspective, a ban is the most effective route and, ultimately, the most cost-effective for society. In the case of lead, the International Labor Organization, the American Public Health Association and the International Society of Environmental Epidemiologists have all issued calls for bans of lead in paint. We believe it is simply false for AIHA to hold that a ban on production of lead paint is somehow inconsistent with our mission as public health professionals. The world’s largest paint manufacturer, PPG, has stated, “There is no reason to put lead in paint” and recently stated it would eliminate such production by 2020.
It is understood that bans can be disruptive and costly. A ban should not be considered lightly, but when a product is in wide use, highly toxic, not used under controlled conditions and has safer substitutes, a ban is warranted.
Consistent with the hierarchy of controls, AIHA should join our allies in other public health fields and support the global ban on lead paint. Scott Schneider, CIH, FAIHA David Jacobs, PhD, CIH for the AIHA Social Concerns Committee
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