ALAN LEIBOWITZ, CIH, CSP, FAIHA, is the president of EHS Systems Solutions LLC, chair of the Joint Industrial Hygiene Ethics Education Committee, current BGC chair, and a past Board member of AIHA. Send feedback to The Synergist.
Ethics of Analysis
Editor’s note: The case study in this article is fictitious and is intended to highlight ethical issues in the practice of industrial hygiene. Any resemblance to real people or organizations is coincidental. Please send your responses to The Synergist. Responses may be printed in a future issue as space permits.
Modern industrial hygienists and other occupational and environmental health and safety professionals have access to an unprecedented amount of data to inform their everyday decisions. Much of that data comes from sources that OEHS professionals could only have dreamt of decades ago. From the 1940s through the 1960s, most practitioners relied on paper sources obtained during their education and perhaps some key, costly references acquired throughout their careers. It was rare for the practicing OEHS professional to have easy access to journals beyond those available through association memberships.
The process of finding and using reliable OEHS data first incorporated electronic elements in the 1970s, when the fax machine became common. But even in the 1980s, reference books were still the primary sources of EHS information, and despite the use of faxes it could still take weeks to obtain a copy of an article, if it arrived at all. Eventually, in the late 1980s, thanks to the availability of desktop computers and online data, electronic access to technical literature slowly became a real possibility for industrial hygienists.
In those early days of computerized data retrieval, a researcher who provided enough background information could have an online search performed, usually by a librarian. If the article in question had been indexed, a copy might be obtained. To make such a request, the industrial hygienist would generally need to know that a relevant document existed or provide appropriate keywords that might unearth unknown research reports. The various data search services included different publications in their search groups, and none were comprehensive. Therefore, even into the mid-1990s, it was most common for OEHS professionals to keep a few key technical reference volumes available as their primary sources of information for evaluating occupational exposure concerns and recommending appropriate protective measures.
After the turn of the century, the volume of data increased exponentially, with more created every few years than had been created throughout recorded history. Today, data can be directly transmitted from sampling locations to laboratories—a wonderful convenience, but one that introduces the possibility of massive errors if initial data are entered incorrectly (for example, reporting the wrong size particle for a selective sampler).
This abundance of data makes fact checking both harder and easier. In 2021, we can find immediate answers to almost any question through the internet, but unfortunately, the answers that are most readily available often have, at best, a tenuous relationship to scientific rigor.
DATA ANALYSIS All professionals develop a set of principles that guide their approach to data analysis. While many sources on sampling design exist, most professionals often need to make decisions with incomplete or less-than-ideal information. It is therefore not unusual to find that, as new data become available, recommended precautions need to be revised.
The history of industrial hygiene is replete with examples of workplace risks identified only after sampling technology or epidemiological analysis had advanced enough that the issue could be detected. The management of this ambiguity becomes an ethical issue when decisions are made regarding how to address previous reporting that proves, upon later analysis, to have been incorrect or insufficient. The following hypothetical scenario illustrates a potential ethical dilemma related to use of data and other information.
DID IKE MAKE PROPER NOTIFICATION? Ike is a relatively new CIH who works on a large team at a major chemical company, where he has been praised for his handling of a major exposure concern. The company’s main production facility had been painted with a chemically resistant coating that had deteriorated over time. It was not uncommon for employees to encounter flaking debris from the coating in many areas of the facility, including the cafeteria. Since, in its unreacted state, the coating was known to include potential sensitizers, Ike was assigned to evaluate the situation and recommend appropriate action.
Ike collected coating samples for analysis. Air sampling identified the potential for inhalation of some of the debris, but laboratory analysis indicated that the cured material would not break down and the sensitizer of concern presented no apparent risk in its present form. Ike presented the data to company leadership and potentially affected employees. He recommended treating the material as a nontoxic dust and recoating deteriorated areas with an inert material. This recommendation was accepted and proved popular with company leadership since, while expensive, recoating was much less costly than stripping the coating from walls throughout the facility.
Now, almost a year after the project was completed, Ike receives an urgent call from the analytical lab. They have discovered that they used incorrect reagents for analysis, based on an error in the electronic form Ike had submitted with the samples. Upon reanalysis, they have discovered that the sensitizer did, in fact, leach from the old cured coating and that, in rare cases, exposure could cause serious concerns for particularly sensitive individuals.
Since the new inert coating was shown to be protective, and Ike has not, to this date, received any reports of illness potentially related to exposure to the original coating, he decides to take no further action.
For discussion: Does Ike have an obligation to communicate this new information? What is his ethical obligation if he informs his management but they choose to only monitor the situation? Does the statistically low probability of harm make a difference? What guidance can you draw from the code of ethics (PDF) to assist your evaluation of Ike’s decision?
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Codes and Principles Ethical codes and principles, like those formulated by member organizations including AIHA and ACGIH, as well as the Board for Global EHS Credentialing (BCG), commonly require that health and safety information be accurately communicated to the best of the professional’s knowledge. The BGC Code of Ethics (PDF) requires that credentialed professionals “recognize and respect the intellectual property rights of others and act in an accurate, truthful and complete manner” with respect to others’ professional work and research.
JIHEEC: Promoting Ethical Practice
The Joint Industrial Hygiene Ethics Education Committee (JIHEEC) promotes awareness and understanding of the enforceable code of ethics published by BGC as well as the ethical principles of AIHA and ACGIH. JIHEEC includes representatives from all three organizations.
JIHEEC is not an enforcement body or resolution board. It serves the profession by bringing attention to and expressing opinions on ethical dilemmas and challenges encountered by industrial hygienists and OEHS professionals.