DEPARTMENTS
ETHICS
ALAN LEIBOWITZ, CIH, CSP, FAIHA, is the president of EHS Systems Solutions LLC, chair of the Joint Industrial Hygiene Ethics Education Committee, current ABIH vice chair, and a past Board member of AIHA.
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 email your responses to The Synergist. Responses may be printed in a future issue as space permits.
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The Heart of OEHS
Minimizing Risk While Combating Disinformation
BY ALAN LEIBOWITZ
Those of us who practice occupational and environmental health and safety are privileged to belong to one of the few professions that can make our communities better places to live through our actions every day. If we do our jobs correctly, we reduce the likelihood that those in our areas of responsibility will suffer adverse impacts resulting either from the work they do or from coming into contact with harmful materials.
Members of our profession use contemporary, science-based knowledge to identify potential causes of injury and work to mitigate those risks. But while total elimination of risk is an admirable aspiration, it is rarely possible to achieve in the real world. The only way to totally eliminate risk is to stop the practice associated with the risk or eliminate the material that might cause the exposure. This is often difficult since most job tasks are performed and most materials are used because they serve key purposes in manufacturing a product or providing a service.
When elimination is not possible, OEHS professionals best serve society by working to reduce potential exposures to levels below those currently understood to cause harm. That understanding relies on the work of toxicologists, epidemiologists, physicians, and others in the allied medical and scientific community who dedicate themselves to finding potential associations between exposures and injury. Then, OEHS professionals are responsible to assess those associations in order to develop and implement appropriate controls intended to reduce the risk to those they serve.
Appreciation of risks and knowledge of how to control them generally evolve over time rather than appear all at once in a flash of inspiration. For example, the first references to potential asbestos hazards connected it with concerns regarding any work that might generate dusts. One of the earliest specific reports of an asbestos-related disease appeared in 1924, describing a condition that was later named “asbestosis.” This condition was generally accepted to be the only potential health impact related to asbestos exposure until the first reports of a possible relationship between asbestos and lung cancer emerged in the mid-1950s. A potential association with the rare cancer mesothelioma was not reported until a few years later. However, the limitations of these initial reports regarding both diseases led to delayed universal acceptance of their association with asbestos exposure until the mid-1960s.
These fits and starts in the development of scientific knowledge can be frustrating to both OEHS professionals and the public we serve. Historic protective actions may ultimately prove to have been insufficient or, conversely, overly aggressive. OEHS professionals can only work with the information they have gathered from respected, science-based information sources. Today, adequate scientific understanding and the consequent reevaluation of mitigation strategies are likely to develop much faster due to improved detection and analysis capabilities.
Responding to the rapid evolution of health and safety knowledge and often the associated regulatory requirements presents a real challenge for identifying and implementing appropriate control measures. This is particularly true given the alarming growth of data sources that subvert the scientific method by lending credence to unsubstantiated theories developed without any support from peer-reviewed research or analysis by competent experts. These sources often offer simplistic, albeit generally false, narratives that can supplant harder-to-follow current scientific and technical explanations. The current COVID-19 pandemic has brought this challenge into even clearer focus. The following hypothetical scenario presents some of the dilemmas we face.
“I’VE DONE MY OWN RESEARCH”
Editor’s note: The status of OSHA’s COVID-19 vaccination and testing Emergency Temporary Standard was in flux at the time this article was developed. For your comments regarding the challenges COVID-19 has presented, please consider the scenario as occurring in the absence of that OSHA requirement.
August is the certified industrial hygienist on the OEHS team at a midsized semiconductor assembly operation associated with Serve-All, a global conglomerate. COVID-19 has presented the greatest challenge their operation has ever encountered, since many employees must work in close proximity to each other and cannot always follow CDC’s social distancing recommendations. Establishing standard, fixed controls has not been possible since the company faces a difficult-to-detect hazard with transmission mechanisms that are literally evolving. This has led to policies that changed appropriately over time as more data became available.
At this Serve-All site, initial quarantining of incoming packages was relaxed when the virus’s surface transmissibility became better understood. Neck gaiters were initially permitted but then banned in favor of more standard respirators or masks. And with full CDC approval, vaccines have now become mandatory for those in the workplace with few exceptions. The vaccine policy not only makes sense from a personal and public health perspective, but vaccination is also likely to be required when the site works on government contracts, and failure to enact it may have a significant impact on insurance costs.
Clay, a talented engineer who many leaders consider essential to Serve-All’s success, has thus far refused to be vaccinated. He has no health issues that would qualify him for the exceptions listed in the vaccination policy but sees changing guidance from CDC and the health community as a poor basis for personal medical decisions. He is technically sophisticated enough not to be generally opposed to vaccination, but he indicates that his internet research has led him to believe that this particular vaccine could have side effects including induced biomagnetism and the introduction of government tracking technology. Moreover, he is concerned that it is still possible to be infected with SARS-CoV-2 even after vaccination. While Clay does not believe all of these theories, their abundance has led him to suspect there must be some truth to a portion of them. August has been tasked with addressing this situation.
For discussion: Should Clay’s importance to the organization play a role in the decision to enforce the vaccination policy? If Clay were to obtain a written doctor’s note that does not include an identified condition, should that allow an exemption from the policy? How does an organization combat scientific disinformation? How does an organization identify necessary exceptions to policies, and if exceptions are permitted, how is it best to address the potential risk they introduce?
JIHEEC: Promoting Ethical Practice
The Joint Industrial Hygiene Ethics Education Committee (JIHEEC) promotes awareness and understanding of the enforceable code of ethics (PDF) published by the Board for Global EHS Credentialling (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.