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LETTERS
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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

THE AIHA BOARD RESPONDS:
The fundamental principle of the industrial hygiene profession remains the anticipation, recognition, evaluation, and control of hazards that impact people in the workplace and in the community. AIHA is a membership-based professional association with a mission to protect worker and community health using knowledge based on strong scientific principles. Our members are fully committed to our mission. 
In January 2016, the AIHA Board of Directors considered a request from the Social Concerns and International Affairs Committees to support an international ban on lead in paint. After discussion, the Board unanimously reaffirmed the long-standing AIHA position to minimize or eliminate exposures through the promotion of the industrial hygiene hierarchy of controls, and not to support bans of specific substances. 
The principles of the hierarchy of controls have not changed: the best means to ensure that workers are protected from a specific hazard is to eliminate the specific chemical or product that creates the hazard. Because of the well-documented health effects caused by exposure to lead or asbestos, most AIHA members would undoubtedly recommend substitution of a less hazardous substance. Using scientific principles to control exposures is a unifying stance for the profession, the association, and our members.
This is not the first time that AIHA, as an association, has been asked to consider supporting a call to ban a specific substance. The scientific merit supporting a request to ban a substance varies greatly from substance to substance. The legislative and social issues related to banning substances are often outside our core expertise and can generate a wide range of opinions from our membership. But emphasizing use of the best control method to reduce or eliminate potential exposure can be applied universally. There are a range of control measures that industrial hygienists may recommend to protect people from hazards; application of these controls to reduce exposures is a core competency of our profession.
AIHA members have become more involved in product stewardship, and AIHA has responded by supporting the creation and growth of the Product Stewardship Society. This organization provides additional avenues to support a life-cycle approach to exposure control. 
With respect to manufactured products containing hazardous substances, the global marketplace has a significant impact on which products are available to consumers. The example given regarding one company’s pledge to eliminate lead from its products by 2020 should be applauded. AIHA expects that industrial hygienists and product stewards will play an increasingly important role in identifying appropriate material substitutions as the marketplace demands these changes more frequently. 
AIHA and the Product Stewardship Society will maintain their focus on controlling exposures through sound industrial hygiene practice and sustainable product design and management, while other associations and organizations will work to support agent or product-specific bans. Collectively, through these various approaches, our public health community will continue to protect and improve the lives and livelihood of our global community. Daniel H. Anna, PhD, CIH, CSP Steven E. Lacey, PhD, CIH, CSP
on behalf of the AIHA Board of Directors

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