The Linchpin
AIHA Adopts a Plan for Improving OEHS Practice
AN INTERVIEW WITH JOHN MULHAUSEN AND MICHELE TWILLEY
BY ED RUTKOWSKI
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During the last few years, AIHA has implemented several long-tail initiatives whose goal is nothing less than the transformation of OEHS science and practice to benefit both practitioners and the protection of workers. While The Synergist has covered each of these initiatives, they overlap to such a degree that it can be difficult for even regular readers to keep the details straight. Here is a brief refresher:
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• Defining the Science identifies research needed to improve the ability of practitioners to protect workers and communities.
• Principles of Good Practice (PGP) documents clear and concise guidance on practices that help OEHS practitioners effectively manage OEHS hazards and risks.
• State of the Art versus State of the Practice (SotAvP) implements a continuous improvement plan to close gaps between current practice and optimal practice performance.
• Improving Exposure Judgments seeks to improve OEHS practitioners’ risk-
assessment abilities.
Work on these initiatives has proceeded simultaneously, fueled by teams of volunteers and informed by surveys and brainstorming sessions. Such an ambitious undertaking risks bogging down without precise coordination, especially when the topic is as broad as OEHS, so AIHA has chosen to focus on one aspect of the profession at a time. Much of the work so far centers on exposure assessment, in part because extensive research already exists in this area. The four initiatives have produced a PGP document as well as a related SotAvP survey (PDF) whose findings clarified where improvements are needed in exposure assessment practices. The survey findings were prominently featured in the January 2024 Synergist.
Now, one year after publication of that article, we turn our attention to another milestone: the recent approval by the AIHA Board of Directors of a continuous improvement plan, which is not only the key piece of the SotAvP initiative but the linchpin that will keep all four initiatives in sync. The plan lists deficiencies in exposure assessment, as identified by the survey findings; establishes metrics and timelines for addressing those deficiencies; specifies actions AIHA will take to achieve those goals; and gauges progress. The plan, details of which are excerpted in Table 1, will be updated periodically to incorporate other areas of OEHS; next in line are respiratory protection and noise and hearing loss prevention.
Table 1. Select Details from the AIHA Continuous Improvement Plan
Tap on the table to open a larger version in your browser.
To learn more about the continuous improvement plan, The Synergist reached out to John Mulhausen, PhD, CIH, CSP, FAIHA, and Michele Twilley, DrPH, CIH. Mulhausen spearheaded the four initiatives during his term as AIHA president in 2021–2022 and has remained engaged with them in the years since his Board duties ended. Twilley, AIHA’s Chief Science Officer and staff certified industrial hygienist, is the staff contact for each initiative. The article on these pages presents Mulhausen and Twilley’s perspectives based on an interview with The Synergist. Responses have been edited for clarity.
THE SYNERGIST (TS): What was the origin of the continuous improvement plan?
JOHN MULHAUSEN (JM): The SotAvP continuous improvement initiative was part of AIHA’s last strategic plan, which covered the years 2022 to 2024, and it will be continued in the next strategic plan, which was a pleasure to see. Ultimately, it’s about AIHA helping the industrial hygiene profession do a better job, to understand and begin closing the gaps between the practices that ensure good protection for workers and the practices that we are actually performing in our workplaces. And so, the State of the Art versus Practice initiative becomes a three-part effort.
The first part is asking, “What are good, recommended practices that effectively manage workplace hazards and risks?” We’ve got the Principles of Good Practice initiative to define those things. The first PGP released was on occupational exposure assessment, so that rolled into the second part of the State of the Art versus Practice, which is to survey practitioners to better understand what we are doing versus what these good practices are recommending we do. That survey was conducted in 2023 and featured in the January 2024 issue of The Synergist.
So now we’re on the third phase of the State of the Art versus Practice initiative. Now that we’ve learned from this survey where our gaps are, let’s define plans and actions that AIHA can put in place to help practitioners close the gap between what is actually happening on the shop floor and the good practices defined in the PGP.
And that’s why we’re so excited about this first iteration of the continuous improvement plan, which is informed by the survey results. Those results are far-reaching with many improvement opportunities. For this initial iteration of the plan, we thought we needed to make sure we have smart, actionable items that have a reasonable chance of success in the next year to five years.
TS: How will the plan be updated?
JM: The vision is that this becomes a continuous improvement planning cycle that pulls in new domains or areas of practice over time. This first one is focused on occupational exposure assessment simply because that was the first PGP developed, but a second survey went out in November 2024 that focuses on understanding how we practice in the areas of noise and hearing loss prevention and respiratory protection versus the recommendations in those two PGPs. That survey will help us understand where the gaps are between actual practice and what the PGPs are recommending for noise and hearing loss prevention and respiratory protection. Then AIHA will define actions that begin to address those gaps in the next iteration of this plan. Looking ahead a year from now, we would expect to see a continuous improvement plan that covers not just occupational exposure assessment but also noise and hearing loss prevention and respiratory protection programs.
TS: Who helped create the plan?
JM: We wanted to bring together representatives from key AIHA stakeholders, including the Board, staff, and volunteer groups. Because this first continuous improvement plan is focused on occupational exposure assessment, we had people from the Exposure Assessment Strategies Committee and the Improving Exposure Judgments Advisory Group, and because part of the PGP covers the use of occupational exposure limits and occupational exposure bands, we also had representatives from the Exposure and Control Banding Committee. Because this initiative is part of the AIHA strategic plan, we had key AIHA staff leadership join the planning process as well as representatives from the Board, including John Moore as the Board liaison to those technical committees and Bryan Seal as the Board representative for the PGP.
TS: The plan identifies an “entitlement” goal for each action. Could you explain what this means?
JM: The idea of “entitlement” is to define the best possible performance that can be realistically achieved within a project. For all kinds of reasons, we’re probably never going to reach a hundred percent of practitioners. But it’s not unreasonable to think that, if we keep working the problem in effective ways, we could reach the vast majority.
The plan also identifies a five-year goal for addressing each gap. These five-year goals are typically shy of entitlement. As we continue to move things forward, we hope to do better and better and better. If we’re really fortunate, we’ll hit entitlement, but our primary objective is to hit those five-year goals within the five-year timeframe.
TS: Some aspects of the plan involve outreach through local sections or student local sections. What role do local sections play in achieving the plan’s goals?
JM: During the Improving Exposure Judgments activities, marketing experts surveyed practitioners to better understand why there are gaps between current practices and best practices. One of their insights was that the people who understood the need for improvement typically had had an “aha moment”—a conversation or exercise or experience that convinced them they needed to make a change. Therefore, a key part of the marketing experts’ recommendation is to create opportunities for those aha moments, which are more than you can achieve by asking someone to read a pamphlet or watch a YouTube video. It requires some back-and-forth and engagement and discussion. Local sections, student local sections, and training institutions are places where we can have those kinds of discussions and that kind of impact with audiences. More than just a traditional marketing effort, it has this dimension of audience engagement and participation to help people understand that change is needed.
MICHELE TWILLEY (MT): The thought was that the CIHs who attend conference for their CM points are hearing the message. Members who are involved in the local section may not be going to AIHA Connect, but they are actively engaged in their section. We really wanted to reach out to where the people are.
The other part of the push is to academics. They have the ability to share training and education. If we create demand for students to learn this skill, we are starting at the very ground zero where people are entering the profession.
TS: AIHA is also planning to initiate a “culture shift campaign.” What is that campaign about?
JM: AIHA and ACGIH started the Improving Exposure Judgments initiative several years ago in order to shift the culture of OEHS practice from one where tools and activities that improve exposure judgment accuracy and interpretation are rarely or sporadically used, to one where their use is routine and expected. That included research and marketing materials to persuade practitioners of the need for change. Those same ideas could be used for improving noise and hearing loss prevention programs or respiratory protection programs. If we’re learning through surveys that we have significant gaps between what we are doing and what our Principles of Good Practice tell us effectively protects workers, then we need to figure out how to drive a change in behavior among practitioners. First, we have to believe in the need for change, and second, we have to engage with the materials AIHA is providing to bring those changes into our practices and workplaces.
TS: What else do Synergist readers need to know about the continuous improvement plan?
JM: I would just say how excited we are to have AIHA behind this initiative to help our profession do a better job. To me, that’s the main thing. We can get all hung up on the details in the plan—is it long enough or short enough or too many things or not enough things—but ultimately the commitment that it represents on the part of AIHA’s Board, staff, volunteer groups, and the association as a whole to help us continuously improve our ability to protect workers is what’s exciting about it.
MT: We have two meetings a year with NIOSH, and it’s a really wonderful partnership meeting. At our last meeting in October, we covered the four initiatives, and we brought up the continuous improvement project. One of the great quotes we got from NIOSH is that “AIHA is doing transformational work.” That was just spectacular to hear.
JM: I think that’s some lovely recognition that AIHA is really putting its money where its mouth is about helping the profession improve. That improvement benefits not just professionals but workers as well, and of course, it comes right back to AIHA’s mission statement.
MT: I also think about the letter to the editor in the December Synergist from a reader who was dismayed about how EPA is getting involved in worker health. You know, a lot of things have happened without us watching. We get complacent in the status quo, that we’re just OSHA compliant, and yet the world is growing up around us, and the threat from chemical hazards has grown, too. And the thing is, we can do better, and we know we can do better. But a lot of us are still in that compliance-oriented mindset, thinking that’s all we have to do to protect worker health, and that’s just not the case.
In October, a few AIHA staff and members of our TSCA Task Force met with EPA, and I delivered a presentation on the similarities between TSCA and our PGP for exposure assessment. It was very well received by the IHs in the audience on the EPA side. They see the value of what we bring, and we were invited back to start digging into occupational exposure limits and how we apply them as a profession. So, EPA is listening, and we have a seat at the table. We are working hard to bring the point of view of the IH in controlling exposures.
JM: We have a tremendous opportunity to do a better job than we’re doing today as a profession. We have a gap between the things we could be doing to ensure that people are protected and what we’re actually doing. And a big reason for that gap is—and I’m not blaming OSHA, because they face extreme headwinds as they try to put in place good regulations—but part of the reason we’re in this place is we’ve been slow to move beyond what OSHA was telling us we need to do as a bare minimum and really thinking hard about how we systematically ensure worker protection. So, EPA is coming into that regulatory vacuum in a way that, at a high level, is a healthy challenge to our practice paradigm. It’s all about how to do a better job at protecting workers. The frustration comes as EPA works through the details.
I think AIHA has an excellent strategy for how to assess and manage occupational exposures. It’s not the same thing that EPA is talking about at this point, but I think we have some real opportunity to influence and align.
If our profession had embraced AIHA’s strategy back in the 1990s when it first came out, we wouldn’t be in this boat. There would not be this huge gap between what OSHA tells us we have to do as a bare minimum and what we actually need to do in order to protect our workers. We’ve had the strategy, but very few of us have picked it up and done the work to actually implement it and make it happen in workplaces. And that’s our profession’s and AIHA’s opportunity. We’ve taken this effective and efficient strategy and used it to define the occupational exposure assessment PGPs, which are much easier to engage with than a big thick book. The PGPs can be used as checklists to help us improve how we assess and manage worker exposures, and they’re very easy to share with EPA and NIOSH. And that stimulates these discussions about moving the profession forward.
This is a long way of saying that EPA is filling a vacuum that we as a profession have let sit there way too long. Do I agree with the details they’re putting in place? No, because I’ve implemented our strategy, and I’ve found it to be very effective and efficient. But I’m optimistic that we now have the tools to engage in a conversation with EPA, NIOSH, and OSHA about the best way to move forward with effective practices to ensure worker protection.
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.
MICHELE TWILLEY, DrPH, CIH, is AIHA’s chief science officer and staff certified industrial hygienist.
ED RUTKOWSKI is editor in chief of The Synergist.
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RESOURCES
AIHA: 2023 State-of-the-Art/Continuous Improvement: Airborne Chemical Exposure Assessment Survey (PDF, 2023).
AIHA: “New Initiatives Aimed at Advancing OEHS Science and Practice.”
AIHA: “Principles of Good Practice (PGP).”
The Synergist: “Filling the Gaps” (January 2024).