Plain Language: The Antidote to Alert Fatigue?
The chemist was already symptomatic when I got the call. The symptoms—drooling, nausea, vomiting, abdominal cramps, and dizziness—were indicative of an exposure that would have been life-threatening without immediate medical intervention. As a toxicologist, I’m tasked with assessing potential long-term risks to a worker in the event of an exposure. It’s also my job to understand how and why an error of this magnitude could have occurred and to advise the company on how to prevent it from ever happening again. The root cause analysis of the incident revealed that the chemist had become ill after weighing a carbamate insecticide without following process controls or donning all required personal protective equipment. The engineering controls were adequate, and the worker had recently been trained on procedures. Why would a trained worker neglect to take relatively simple precautions? The article “Why Don’t People Just Follow the Rules?” by Imogen Stanfield and Dr. Rod Gutierrez suggests one explanation. Stanfield and Gutierrez note that workers tend to habituate to their environments, similar to the way we might eventually stop noticing the sensation of clothes on our skin. If information is repetitive, our brains catalog it as unimportant, no matter how critical that information might be for personal safety. With respect to hazard communication, this is commonly known as “alert fatigue.” Additionally, the COVID-19 pandemic taught us that compliance with safety measures—even when mandated by local, state, or federal regulation—can and will be disregarded when people lose confidence in the source of the mandate or can’t understand its necessity. Expertise and authority alone are not enough. To be effective, we must gain and maintain the confidence of those we seek to protect and ensure they comprehend both hazards and risk. Context and Consequence So, back to the incident. How and why did this happen? Can it be attributed solely to a lapse in judgment? The root cause analysis did, in fact, identify a lack of comprehension of the hazards as a key factor: the chemist assumed the small quantity of the material being handled posed no risk. When it comes to risk communication, context and consequence matter. For example, seat belt laws are widely understood. We understand the consequence of inaction, such as a greater risk of injury or death in the event of a crash, and therefore accept the inconvenience of the preventive action. What if we apply that same approach to chemical hygiene? What if we, as OEHS professionals, explained the attributes of a chemical as clearly as possible using plain language so workers fully understand the potential effects of exposure? Plain language is not just good practice; it is, in some contexts, legally required. The Plain Writing Act of 2010 stipulates that U.S. governmental agencies must use language that is easy to understand. The act defines plain language as “writing that is clear, concise, well-organized, and follows other best practices appropriate to the subject or field and intended audience.” Can the audience find what they need? Understand what they find? Use what they find to meet their needs? If the answer to those questions is not yes, then it’s not plain language. Plain language is not “dumbing down” and should not be described as such. That phrase implies our audience is not intelligent. Plain language is more accurately described as a common language. To find that common language, we must first consider our audience, their level of technical expertise on the topic of discussion, and our goal. For example, in communicating an occupational exposure limit to industrial hygienists, I take into consideration that my audience is a group of highly trained non-toxicologists. I make a conscious effort to avoid overly technical jargon. More importantly, I never lose sight of my primary goal: I want the industrial hygienist to understand why I am making a particular recommendation. With that goal in mind, the communication is often like a three-minute elevator pitch, providing context and the most important points. Regarding whether plain language communication can improve compliance with safety protocols, a pharmaceutical contract manufacturing organization I worked with decided to test that hypothesis. They believed that hazard communication briefs, clearly explaining the hazards of an active pharmaceutical ingredient and why the prescribed handling and controls were necessary, would improve worker confidence in the necessity of those controls and increase their overall vigilance.
OEHS is a profession that relies on influence more than authority. To achieve our goal of protecting worker health, we must examine how we communicate.
Sharing these plain language hazard communication briefs, as well as the discussion that followed, gave workers the freedom to speak up and ask questions if something didn’t make sense. The straightforwardness of these briefs made instructions easy to grasp and signaled to workers that their feedback was welcome. Ultimately, this increased confidence in the industrial hygiene program and improved its efficiency. In addition to greater compliance with handling and controls, workers started looking out for as-yet unrecognized hazards and sending queries when in doubt.
At first glance, such an approach may seem conceptually desirable but technically impractical. That’s where occupational toxicologists can support OEHS professionals: plain language hazard communication briefs can be an indispensable part of preventing workplace exposures.
Comprehension and Compliance Let’s rewind to our earlier example of worker exposure and apply this theory to real life. How could we have communicated more clearly to the chemist?
Hazard communication that includes context and required actions can be effective in ensuring worker comprehension and compliance. The following plain language brief might have convinced the chemist to follow handling and controls:
Carbamate insecticides work by inhibiting an enzyme (acetylcholinesterase) that is essential for normal nervous system function. These insecticides can be absorbed through the skin and through the lungs and can cause life-threatening effects from very small exposures. Early symptoms of exposure are muscle weakness, dizziness, and sweating. Constricted pupils (a condition called miosis), often with blurred vision, incoordination, muscle twitching, slurred speech, and drooling, can also occur. These symptoms require medical intervention. Follow all handling instructions and wear all required personal protective equipment.
For the sake of efficiency, handling and controls are often communicated in shorthand through the use of a control band. Control bands specify whether open handling is acceptable and in what quantities, and what minimum PPE is required. Often, the control band for a chemical is marked on the safety data sheet or reported in a database without further explanation.
What if a brief, one-paragraph abstract was made available to provide greater context? Attaching a short summary of the control band rationale to the SDS allows the worker to see the instruction, the explanation, and the source data all at once. Importantly, the rationale should be written in a manner consistent with the internal banding procedure.
Part of the challenge is knowing how to encourage this type of plain language communication from toxicologists and other subject matter experts (SMEs). The first task is to set expectations by reminding the SME of the audience, their level of technical expertise on the topic of discussion, and the goal of the communication. When preparing a document, a simple, three-step exercise can help clarify matters:
Audience: Who is going to read this document? Technical expertise: How much does the audience know about this topic? Goal: What do you want the audience to be able to do after reading the document?
I challenge all OEHS professionals to review their work product with those three questions in mind. Clarity in communication does not occur spontaneously, but only through diligent practice.
OEHS is a profession that relies on influence more than authority. To achieve our goal of protecting worker health, we must examine how we communicate. Equipment can fail, and accidents do happen. Effective communication of the hazards can be the difference between workers following all procedures and a life-threatening exposure.
RENEE HARTSOOK, PhD, DABT, is a consulting toxicologist at Takmos LLC. The expert contributions of freelance technical writer Alejandra Wilcox are gratefully acknowledged.
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Harvard T.H. Chan School of Public Health: “The Need for Effective Risk Communication Strategies in Today’s Complex Information Environment” (January 2018).
Public Law: Plain Writing Act of 2010 (PDF, October 2010).
ResearchGate: “Why Don’t People Just Follow the Rules? The Psychology of Safety Management” (September 2012).