READER RESPONSES One problem in being on the loss-control side of the business ledger is that our value to the organization in preventing errors can conflict with the highly incentivized goals of getting work done on time and within budget that motivate our coworkers. Spectacular examples of bias against being socially inappropriate include the rocket scientists who did not object to the Challenger launch, Volkswagen engineers who did not object to installing defeat devices, and Boeing test pilots who did not insist on the need to retrain 737 MAX pilots.

While Ike’s dilemma is not nearly as spectacular, he is in the position of having the special expertise the organization is depending on to prevent a costly mistake. It is his job to raise this issue to the organization’s decisionmakers. No one else will. The Institute of Nuclear Power Operators (INPO) promotes a concept called “maintaining a questioning attitude” that aims to overcome this bias. Experts need to maintain rigorous processes for examining their assumptions. INPO encourages member organizations to adopt policies for declaring “unresolved safety questions” that trigger formal investigations to resolve problems, similar to accident and incident investigations.

The only way to prevent mistakes from being repeated is to acknowledge them and understand their cause. If Ike chooses to avoid conflict and work the problem himself, he will have lost an opportunity to improve the organization’s health protection program.

The BGC Code of ethics is not particularly helpful in providing guidance in this case. It does require the CIH to maintain high standards of integrity and professional conduct. It also requires compliance with “laws, regulations, policies and ethical standards governing professional practice.” Additional clarification would be helpful.

Not knowing specifics, it is difficult to argue that communicating the new information to workers is a regulatory requirement. Also, regulations represent the minimum standard. So even if the standards do not require employee hazard communication in this case, the employees should be informed. Ike needs to think in terms of doing the right thing. His concern appears to be that the employees will not react well to the new information, and he does not want to admit that a mistake happened. But what will happen to the company’s and Ike’s credibility when the employees learn the new information was withheld? He should report the new information to management and the employees. Ike needs to prepare a compelling argument for reporting if management wants only to monitor the situation. The fact that this situation involves a statistically low probability of harm is not relevant.

Ike has to inform employees and management of the latest findings and revisit the previous action. Management will determine whether they need to do anything about these new findings.

Ike has an obligation to inform employees and management of this new information. He should incorporate appropriate risk communication into the conversation regarding the potential for any employee exposure. He should research the toxicological effects of the sensitizing material and reach out to medical resources to identify applicable surveillance methods to evaluate employee exposure. He should also make recommendations for moving forward with respect to the adequacy of the existing controls (recoating the area with the non-toxic materials) and additional air sampling plans for activities that may produce airborne exposure of the potential sensitizing material.