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.

Acknowledging and Addressing Our Blind Spots
Industrial hygienists have high standards when it comes to sampling and analysis. We insist on sampling using a validated NIOSH method and require that those samples be analyzed by laboratories accredited through an entity such as AIHA’s Laboratory Accreditation Programs, LLC. Accreditation signifies that a lab has met performance criteria from a rigorous third-party review, which helps ensure that the data we receive from labs is accurate—a consideration of the utmost importance, since our recommendations for protecting worker health are based on that data.
However, our insistence on rigorous quality control doesn’t always extend to other aspects of our exposure risk assessment and management (ERAM) processes. We have blind spots that obscure the need for similar objective quality assurance for the important steps that occur both before and after sampling and analysis. Basic characterization of the hazard, formulation of an assessment strategy, judgment of exposure risk, and intervention decisions are just as significant as the sampling method we select and the quality of the lab we use. Yet we seem reluctant to hold these elements of our practice to the same high standards we apply to the labs that analyze our samples. How many IH programs follow systematic, comprehensive, and well-documented ERAM processes that could withstand the same third-party scrutiny that we expect of our labs? The answer, I suspect, is far fewer than we care to admit.
DEMONSTRATING PERFORMANCE A key aspect of quality control for labs is their accuracy performance in proficiency testing such as that conducted by AIHA Proficiency Analytical Testing Programs, LLC. Again, the gap between what we expect labs to do and what we ask of ourselves is telling as few of us have quality control systems in place that objectively demonstrate the accuracy performance of our processes for making exposure risk decisions.
Rigorous quality control in IH would require using statistical tools whenever making exposure judgments with monitoring data, implementing quality assurance processes for our qualitative exposure risk decisions, and subjecting ourselves to feedback on the accuracy of our judgments. But few of us engage in these activities despite the availability of free tools for improving exposure judgments.
We seem reluctant to hold elements of our practice to the same high standards we apply to the labs that analyze our samples.
We have to ask ourselves whether it is hypocritical for us to demand that labs implement rigorous quality control while giving ourselves a pass on other aspects of the ERAM process that are just as critical to the protection of workers. Those of us who have attained the CIH may feel that the competency demonstrated by this credential alone is sufficient. Yet the bench chemists in IH analytical labs are also supremely well trained, and we rightly expect them to submit to the rigors of third-party quality control assessment anyway. As I discussed in my January article on standards of care, competence does not equal performance. What we actually do is more important than what we know.
ACKNOWLEDGING AND SOLVING THE PROBLEM The blind spots that prevent us from acknowledging deficiencies in our IH programs are a typical human failing. We all struggle to admit our faults. But acknowledging the problem is necessary for solving it, and until we do, some of the workers we protect will pay the price.
It is time to acknowledge our blind spots and move quickly to put quality control systems in place for the entirety of our ERAM processes. We have authoritative guidance from AIHA’s A Strategy for Assessing and Managing Occupational Exposures that identifies key elements of a robust and comprehensive strategy—including quality assurance aspects that we should all be incorporating into our practice. To get us started, AIHA and ACGIH are initiating an effort to drive awareness and routine use of the tools and techniques that will increase the accuracy of our exposure risk decisions—a big first step in our improvement journey. More information about the Improving Exposure Judgments Advisory Group is available on the AIHA website.

AIHA: A Strategy for Assessing and Managing Occupational Exposures, 4th ed. (2015).
AIHA: “Top 10 Imperatives for the AIHA Exposure Risk Management Process” (webinar, 2021).
The Synergist: “Faulty Judgment” (November 2021).
The Synergist: “How to Improve Exposure Judgments” (December 2021).