JOHN MULHAUSEN, PhD, CIH, CSP, FAIHA, retired in 2018 from 3M where he worked for 31 years in a variety of global health and safety risk management roles, most recently as director of corporate safety and industrial hygiene. Send feedback to The Synergist.

Occupational Exposure Banding: No More Excuses
My January Synergist article presented an example of two OEHS practitioners with similar backgrounds but different approaches to IH programs: Practitioner A pursues regulatory compliance by seeking to control exposures below OSHA’s permissible exposure limits, while Practitioner B sets a goal of driving exposures below ACGIH threshold limit values. The point of the simplistic example was to illustrate how standards of care—the minimum expected performance of a particular function—influence our interventions and help determine how protective our programs will be on the shop floor.
This month’s column concerns what happens when we’re dealing with a substance that does not have an OEL. We all know that this situation is quite common: the gap between the number of chemicals in commerce and those that have OELs is vast and getting larger every year. Fortunately, an effective approach exists for these substances, but distressingly few OEHS professionals are taking advantage of it.
VALIDATED QUANTITATIVE EXPOSURE GUIDANCE Occupational exposure banding is the process of assigning chemicals, based on their toxicity and hazard characteristics, into categories or bands that define ranges of exposure concentrations that are expected to protect worker health. In recent years, NIOSH has developed and validated a process for generating an occupational exposure band, or OEB, for chemicals that have no OELs. The accompanying e-Tool guides users through the tiered process of assigning chemicals to one of five OEBs. A simple “Tier 1” process is intended for use with substances with established hazard statements in the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). For chemicals without appropriate GHS hazard statements, the e-Tool guides the user through a structured “Tier 2” process of data collection and interpretation to assign an appropriate OEB.
The gap between the number of chemicals in commerce and those that have OELs is vast and getting larger every year. Fortunately, an effective approach exists for these substances.
The e-Tool is a remarkable achievement. It provides a freely available semiautomated process for generating risk-based exposure guidance for chemicals without OELs that has been validated by experts. We should be tripping over ourselves to learn and use the e-Tool so we can better protect our workers and communities. But my conversations with AIHA members and other OEHS professionals indicate that many have no plans to incorporate occupational exposure banding into their practice. Their reasoning typically includes at least one of these arguments:
“OSHA doesn’t require it.” This objection is surprising given the frustrations many of us share about OSHA’s inability to update its PELs, most of which are decades old. Refusing to use a tool because it isn’t required by regulations reflects the mindset of Practitioner A. Do we really want to resign ourselves to practicing our profession with science that was state of the art in the 1960s?
“It’s only for the most distinguished experts.” This may have been true in the early days of occupational exposure banding, but the e-Tool has been designed for use by OEHS professionals without extensive toxicology knowledge. While a Tier 2 assessment can require several hours, this time is very well spent considering the alternative with substances that have no OELs is to throw up our hands and do nothing.
“I don’t see it being done routinely in major organizations.” This objection ignores the history of occupational exposure banding, which has been used for decades in the pharmaceutical industry to safely manage materials for which there are no OELs.
OUR OBLIGATION If you’re new to occupational exposure banding, I encourage you to review the background information on the AIHA website and the resources listed on this page. To those who resist occupational exposure banding, I urge you to reconsider. We can’t simply ignore exposures when OELs are unavailable. Our profession owes workers and communities better protection. Change is hard, and the excuses are endless, but our professional credibility and ethical obligations demand progress.
AIHA: A Strategy for Assessing and Managing Occupational Exposures, Chapter 25, “Occupational Exposure and Control Banding,” 4th ed. (2015).
AIHA: “Occupational Exposure Banding: What You Need to Know.”
AIHA: “Top 10 Imperatives for the AIHA Exposure Risk Management Process” (webinar, 2021).
NIOSH: “NIOSH Occupational Exposure Banding e-Tool.”
NIOSH: “Occupational Exposure Banding: Overview.”
The Synergist: “The Banding Marches On” (May 2014).
The Synergist: “Hyped About Hazard Banding: The Promise and Perceptions of a Misunderstood IH Tool” (October 2009).
The Synergist: “The NIOSH Decision Logic for OEBs: Applying Occupational Exposure Bands” (March 2016).