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News + Events

The Galson Blog

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Bill Walsh CIH

05/09/2014

Adventures at the U.S. Department of Labor


On April first I had the experience of testifying about the proposed new silica standard at the U.S. Department of Labor in Washington DC.  I did this in my role as Vice-Chair of the Analytical Accreditation Board, testifying on the portion of the proposed standard requiring a lab to be accredited. 



However, because an industry group submitted a study suggesting that “AIHA labs could not accurately analyze silica at the proposed levels”, much of my testimony revolved around the validity (or lack thereof) of this study.



First of all, it was a political exercise with very little hard science involved.  The room was evenly divided between those against the proposal and those in favor of it (basically industry versus labor). The point of the testimony was to get statements supporting a position into the record while nullifying or at least minimizing the impact of an opposing statement.  This is probably pretty obvious to everyone, but it was surprising to actually see it in operation. It was also REALLY surprising to see people, who I know do silica analyses on a daily basis, perform as hired experts saying the method was inaccurate.  I’ve talked to some of them and some were quick to state their opinion was pertaining to the 25 microgram proposed PEL, others were trying to establish themselves as “friends and knowledge resources for the industry”, and some just wanted to take the money and run. 



My testimony consisted of reading a prepared statement and then answering questions.  Due to time constraints, my reading of the statement was stopped and the rest was just entered into the record.  This was done so that the audience and the OSHA panel could ask me questions. This brings up my second point.  The judge and the OSHA panel had to have the patience of Job to sit there for three weeks and listen to person after person read testimony in what was usually a dry, monotone manner influenced by their ability to read.  I listened for two hours prior to probably doing the same thing and it was painful.  Those people had been doing this for THREE WEEKS!  Anyway, when the judge said to move on to the Q&A, the energy in the room increased dramatically.  This was obviously the fun part and why everyone had come.



I answered the questions to the best of my ability (I am quite familiar with the analytical method, instrumentation, and the submitted study).  The questions tended to be more statements than questions and the judge stopped the questioners several times, at one point actually saying, “Are you asking a question or testifying”.  Again, the point of the exercise was to get your viewpoint into the record.  I enjoyed it as I was sure of my facts and enjoy a good verbal tussle.  I would enjoy doing it again.



Here is my opinion of the proceedings:



1)      Nothing may happen for a couple of years.  It is my understanding that now that the comment phase is over, it can be up to two years before the final rule is issued, at which time multiple lawsuits may ensue.  If the IH community is frustrated with the length of time it takes to promulgate a new standard, believe me, many people at OSHA are just as frustrated.  Although I’ve always suspected it, actually seeing the building of the political roadblocks was enlightening (and a little sad from a professional viewpoint).



2)      No one is absolutely wrong in this debate.  The current standard is completely outdated.  But industry is correct in that the current regulations have not been enforced properly.  Just today I had a phone call from a CIH who talked about a road construction project where the cement cutting produced a cloud that was almost impossible to drive through and covered a whole neighborhood.  Obviously this violated a whole slew of standards (PM10, Total Dust, Respirable Dust) beyond silica.  The situation could have been easily rectified in this area because water to do wet cutting was readily available – where was the enforcement of current standards.  I somewhat agree that the good guys spend the money and are affected by the standards, while the people endangering their employees are less affected.



3)      It is REALLY important that the lab you use be accredited to ISO 17025.  This at least lays a ground work for quality results. Just remember that accreditation does not guarantee accuracy.  It is a basement standard of performance, not a ceiling.



4)      Just because the lab is accredited, that doesn’t mean they will be good at what they do (although it helps).  As in anything else, picking a lab is “buyer -beware” and you have to do your homework. Ask to see your lab’s QC data on intra-batch samples, LOQ studies, and ask them how they deal with all the interferences known to be a problem.



5)      I am absolutely confident that the analytical method can be done with acceptable accuracy and precision.  I am just as sure that it produces horrible accuracy and precision if not done CAREFULLY.  Sample prep is critical as are the instrument parameters used to analyze the samples.  Silica analysis is a perfect example of “haste makes waste”.  A great deal of variation can be  caused in the step where the sample is redeposited from the collection filter onto the silver membrane filter used in the analysis.  It has to be slowly and carefully done. 



6)      In the same manner, good labs assume there will always be an interference and proceed accordingly, including a muffle furnace or similar step in the digestion procedure.  PAT samples have some interference present in them. Labs that don’t take this into account will get burned, as will the people who use them. Again, Caveat Emptor. However, not informing the lab about where a sample has been taken and if any KNOWN interferences are present is just tying one hand behind the lab’s back.



7)      I am ABSOLUTELY confident in Galson’s ability to produce accurate and precise results at a PEL of 50 micrograms per cubic meter.  I also believe that we could produce valid data at a level of 25 micrograms per cubic meter, with a few more method modifications. I am just as certain the other labs that I’ve been associated with over my 30 year career also generate good data (although a paid expert from one of those labs testified otherwise!).  I am also just as confident that there are some labs that simply do not do the analysis correctly.



8)      Do your homework, ask the right questions, inform the lab about where you are taking the sample and what possible interferences there may be, and you’ll get great results.  And, that applies to any lab analysis.



 


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Edward Stuber CIH

05/05/2014

California Department of Public Health Recommends Lowering Cal/OSHA PEL for Lead


​Here is something that is not getting much play in the Health & Safety community – at least I have not heard much about it. Back in November 2013, the California Department of Public Health’s (CDPH) Occupational Lead Poisoning Prevention Program (OLPPP) recommended a significant reduction to Cal/OSHA’s permissible exposure limit (PEL) for air lead levels in the workplace. The OLPPP is recommending workers’ exposure to lead in air be kept at or below 0.5 to 2.1 micrograms of lead per cubic meter of air (µg/m3). The current Cal/OSHA PEL, as well as the Federal OSHA PEL, is 50 µg/m3.  Stop and think about that for a minute. The OLPPP is recommending up to a 100X reduction of the current Cal/OSHA PEL for lead. WOW!



OLPPP is saying their recommended PEL is based on its determination that having chronic blood lead levels (BLLs) at or above the range of 5 to 10 micrograms per deciliter (µg/dL) poses a health risk to workers. The proposed PELs were obtained from risk modeling results performed by the Office of Environmental Health Hazard Assessment (OEHHA). The OEHHA estimated the concentrations of lead in air that would result in BLLs of interest over a 40-year working lifetime. They came up with 0.5 to 2.1 ug/m3 of lead in air values.



If CAL/OSHA implements this proposed change, it could mean big things for the lead analysis (ie IH lead laboratory) community. Currently labs can meet the CAL/OSHA and Federal OSHA lead PEL of 50ug/m3 by using relatively inexpensive equipment, such as Flame AA instruments. By using this inexpensive technique, labs can charge a low rate for the analysis. If the new PEL is implemented, labs will have to use the more expensive analytical techniques of graphite furnace or ICP, ICPMS.  This would add considerable cost to the sample analysis.  Something to think about. I am all for protecting the worker and if it means lowering PELs, then so be it.



For more information, you can read OLPPP’s recommendation here


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Edward Stuber CIH

04/23/2014

NHL – National Hockey League - aka as the National Hospital League


You remember the old saying – “I went to a prize fight and a hockey game broke out.” That saying has less meaning in today’s game of professional hockey. The winding down of the professional ice hockey season and into the playoffs is highlighted by a report has been released detailing the injury rate and cost of injuries in the NHL.  The study covers the previous 3 seasons (2009-2010, 2010-2011, and 2011-2012) of the NHL.  If you ever watched a professional hockey game (much better in person than TV), you know what a violent game this is.



Up until recently, head hunting, goons, and prolonged fights were the norm ( some say encouraged) and expected during games.  Recently the NHL has tried to implement   rules to safeguard the players from many of the preventable injuries (with concussions being the most prevalent), but based upon the injury numbers, more needs to be done to safeguard the players. Not only will stricter rules make the workplace safer for the players, the owners will benefit from lost-time due to injury.



The study included over 1,300 NHL players   who played at least 1 game during the 3 years studied. More than half of these players missed at least one game due to an on the job injury. These on the job injuries cost the NHL roughly $218 million a year.  Concussions alone cost almost 43 million!  All of this happened during the newly instituted enlightenment period in the NHL where the powers that be made an effort to reduce these injuries. Imagine what the numbers were in the past!



This shows that more player protection is needed. Larger fines, stricter rules, and other changes need to be implemented to make the hockey rink a safer sports environment. The complete study can be found in the January 2014 edition of Injury Prevention.



These rule changes have not hurt the game in terms of attendance and revenue, as some people feared - so there is no reason more protection cannot be implemented for the workers (players).  I am all for providing a safe and healthy work place for all workers – including hockey players.


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Joe DeLeo

01/30/2014

A Cup of....Mold?


I love coffee!  It really helps to get your day started right and for me personally allows much better focus and mental clarity. Now I am a very energetic person so one cup does wonders for me. Lately though I have noticed some interesting effects from coffee. I’ll get my brain and body revved up with a kick and then come crashing down.



I catch myself in a daze and usually have a bit of brain fog as well. What I noticed is that these symptoms occurred only after having coffee at places such as Starbucks or Dunkin Donuts. When I purchased coffee from local cafes these symptoms never occurred. I investigated further and found that I was most likely experiencing symptoms from mycotoxins in the coffee beans. Read more here.



It all boils down to the fact that coffee doesn’t control for processing methods or the source of the beans and mold can grow on coffee beans which is a great environment for mycotoxins to flourish. Read more here.



This leads to all sorts of health problems such as cardiomyopathycancerhypertension, kidney disease, and even brain damage.



Mold can affect our health in many forms. At Galson Laboratories we focus on testing air quality and providing the data that protects workers. While you are probably reconsidering where you buy your coffee, take a few minutes and check out our website and learn more about how we can help you determine if your business, home, or other environment is suffering from mold exposures that are affecting your air and causing respiratory health issues. Chat with a client service representative to learn more!



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