Occupational Safety and Health Standards

If we are to approach developing a safe and healthful workplace in a more timely fashion, a more generic approach must be considered and applied instead of developing recommendations and standards simply on a substance-by-substance basis, an approach that has been the most prominent. Some examples in which developing generic standards may be appropriate are: cholinesterase-inhibiting substances, neurotoxic agents, reproductive hazards, cold environments, and vibration syndrome, to name but a few. It is important to recognize that developing standards based on individual substances often does not allow for the role of synergism, a reaction that has had little study, but it is important in controlling occupational disease and injury. These concerns can be addressed in several ways. One is to look at processes or conditions found in the workplace; for example, coke oven emissions that OSHA has promulgated into a standard and, as NIOSH has done in their recommendations to OSHA for foundries, coal tar products, the manufacture of paint and allied coatings, field sanitation, hazardous waste management, hot environments, and confined spaces. Another is to address groups of similar substances such as NIOSH has done with alkanes, benzidine-based dyes, diisocyanates, dinitrotoluenes, and glycol ethers. A third comprehensive approach is to look at general categories of hazards, such as the generic carcinogen policy, and the hazard communication rule. Finally, risk must be considered in the development of any standard. Nelson Rockefeller once said in relation to an incidence involving a radiation hazard that, "you can't have a riskless society." I would amend this to say that you cannot have a reckless society either. Safety and health regulations are essential and must be designed, promulgated, and then enforced so that a reckless society is avoided or controlled, with a riskless society being the ultimate aim.