Niosh Control Banding
Niosh Control Banding
Niosh Control Banding
Disclaimer
Mention of any company or product does not constitute endorsement by the National
Institute for Occupational Safety and Health (NIOSH). In addition, citations to Web
sites external to NIOSH do not constitute NIOSH endorsement of the sponsoring
organizations or their programs or products. Furthermore, NIOSH is not responsible
for the content of these Web sites.
Ordering Information
To receive documents or other information about occupational safety and health topics,
contact NIOSH at
Telephone: 1800CDCINFO (18002324636)
TTY: 18882326348
E-mail: [email protected] or visit the NIOSH Web site at www.cdc.gov/niosh.
For a monthly update on news at NIOSH, subscribe to NIOSH eNews by visiting
www.cdc.gov/niosh/eNews.
DHHS (NIOSH) Publication No. 2009152
August 2009
SAFER HEALTHIER PEOPLE
ii
FOREWORD
When the U.S. Congress passed the Occupational Safety and Health Act of 1970 (Public
Law 91596), it established the National Institute for Occupational Safety and Health
(NIOSH). Through the Act, Congress charged NIOSH with recommending occupational
safety and health standards and describing exposure levels that are safe for various
periods of employment, including but not limited to the exposures at which no worker
will suffer diminished health, functional capacity, or life expectancy as a result of his
or her work experience. NIOSH communicates recommended standards to regulatory
agencies (including the Occupational Safety and Health Administration [OSHA]),
health professionals in academic institutions, industry, organized labor, public interest
groups, and others in the occupational safety and health community through criteria
documents. Yet limited resources, incomplete data, and the ever-expanding inventory
of chemical hazards in the workplace and global commerce make it infeasible to develop
standards for all possible hazards. Consequently, NIOSH has also been tasked with
assessing and providing technical solutions and promising intervention strategies to
protect the safety and health of workers.
One such emerging strategy has gained increasing attention among safety and health
practitioners: a qualitative risk characterization and management strategy, also referred
to as control banding (CB). This strategy groups workplace risks into control bands
based on evaluations of hazard and exposure information. The utility of CB is recognized
by a number of international organizations, and widening interest can be gauged by the
growing literature describing qualitative risk assessment and management strategies.
Despite limitations, in the absence of recommended standards, CB may be a useful
strategy for assessing and controlling occupational hazards as part of a comprehensive
safety and health program.
This document is generated from literature reviews of recent developments describing
such exposure-characterization and risk-management strategies in occupational
settings. In particular, this document summarizes the literature describing qualitative
risk assessment and strategies of risk management. The intent of this review is to provide
a broad description of qualitative strategies to reduce risk of exposure to occupational
hazards, recognizing that a deliberate and extensive review of the literature on this
topic will help guide decisions for where CB applications may be most effective. Also
important is finding where limitations in our understanding may require additional
research or modification or may preclude the use of CB strategies altogether. In meeting
these objectives, this document intends to inform its audiencemostly occupational
safety and health practitioners, researchers, policy and decision makers, employers, and
iii
workers in potentially hazardous work placesof the concepts of CB and the promise
it holds as a tool for use within a broader comprehensive occupational safety and health
program.
iv
EXECUTIVE SUMMARY
The majority of chemical substances in commerce have no established occupational
exposure limits (OELs). In the absence of established OELs, employers and workers
often lack the necessary guidance on the extent to which occupational exposures
should be controlled. A strategy to control occupational exposures that may have value
when there are no relevant OELs is known as control banding (CB). CB is a qualitative
strategy for assessing and managing hazards associated with chemical exposures in the
workplace. The question about the utility of the CB strategy for workplaces in the United
States has been raised, warranting a critical review of its concepts and applications. This
report is the result of a review of the published literature and related proceedings on CB.
The conceptual basis for CB is the grouping of chemical exposures according to similar
physical and chemical characteristics, intended processes/handling, and anticipated
exposure scenarios (amount of chemical used and how workers would be exposed).
Based on these factors, appropriate control strategies (that is, risk management options)
are determined for each of these groupings. In one of the least complex forms, a four-level
hierarchy of risk management options for controlling exposures to chemicals includes
1. good occupational hygiene practices, which may be supplemented by use of
appropriate personal protective equipment (PPE)
2. engineering controls, including local exhaust ventilation (LEV)
3. containment
4. seeking specialist advice
To determine the appropriate control strategy, one must consider the characteristics of
a particular chemical substance and the potential for exposure (based on quantity in
use, volatility [for liquids], or dustiness [for solids], and the relative hazard as described
in what is known as a risk phrase, or R-phrase). Determining potential exposures for
airborne particulates or vapors involves characterizing the process or activity in which
the chemical substance is used. Work processes help in assigning the chemical substance
to a CB. These CBs provide guidance for various control options and recommendations
for PPE based on a qualitative assessment of the chemical exposure.
The published literature on CB revealed different models, each with varying levels
of complexity and applicability. The utility of qualitative risk management strategies
such as CB has been recognized by a number of international organizations. Widening
interest in this strategy can be gauged by the growing literature describing elements of
qualitative risk assessment and management strategies and in some cases, very welldeveloped models of practice. This report attempts to capture the state-of-the-science of
CB as reflected in research and practice. From the published literature and information
gleaned from proceedings of recent international workshops, symposia, and conferences
on this subject, the following major themes related to CB have emerged:
v
vi
In summary, this review and analysis have led to recognition of the following key
messages:
Control banding is a potentially valuable tool for risk management of source
chemical agents and other occupational hazards.
Despite limitations, in the absence of OELs, CB may be a useful strategy for
assessing and controling occupational hazards as part of a comprehensive
safety and health program.
CB is not meant to be a substitute for OELs.
The use of CB does not alleviate the need for environmental monitoring and
industrial hygiene expertise.
CB strategies may be useful for providing hazard control guidance to small and
medium size enterprises (SMEs); larger businesses may find CB strategies of
greatest utility for prioritizing hazards and for hazard communication.
Additional development, evaluation, and discussion are required before widespread
implementation of CB in the United States can be recommended. This document is
intended to set the stage for that discussion. At this time, the existing toolkits for CB may
not be appropriate for the United States and will need modification before being applied.
Critical is the need for a dynamic system that incorporates changing factors over time
for both control implementation and managerial oversight. It is recommended that a
taskforce of safety and health professionals, labor and management, and government
representatives be established to advance the research and development needs for CB
in the United States.
vii
CONTENTS
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii
Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv
Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xvi
Exposure Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2 | Problems Implementing Measures to Limit Workplace Exposures . . . . . . . . . 3
8
8
9
9
9
9
11
13
14
16
16
17
18
19
21
23
24
24
27
30
ix
5.1.1
5.1.2
5.1.3
5.1.4
5.1.5
Exposure Prediction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Hazard Prediction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Control Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Control Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
33
33
33
34
34
34
34
35
36
36
38
Dermal Absorption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Silica (HSE) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Asthmagens (HSE, NIOSH, OSHA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Asbestos Essentials (HSE) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
41
43
44
44
45
46
46
47
47
49
49
51
51
51
52
52
53
8.2 Determine the Barriers to, and Considerations for, Implementing Control
Banding to Address Safety and Health Hazards in U.S. Workplaces . . . .
8.2.1 Use of Standardized Hazard Statements in Control Banding . . .
8.2.2 Considerations for Implementing control Banding . . . . . . . . .
8.2.3 OSHA and Its Voluntary Consultative Services . . . . . . . . . . . .
8.3 Implementation of a Risk Management System in the United States that
Includes CB Strategies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.3.1 Can Toolkits and Toolboxes Reduce Occupational Exposures
to Protect the Health of Workers on a National Basis? . . . . .
8.3.2 Implementation in Small Businesses . . . . . . . . . . . . . . . . . . . . .
8.3.3 Expanding to an ORM for Chemical Control . . . . . . . . . . . . .
8.3.4 Develop Ergonomic Toolkits Based on Existing
National Models . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.3.5 Investigate Expansion to Safety and Environmental
Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.3.6 Investigate Expansion to Psychosocial Toolkits . . . . . . . . . . . .
8.3.7 Implementing a National Control Banding Strategy . . . . . . . .
8.4 How Can International Cooperation Assist in the Creation of
Toolkits and ORM Toolboxes? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.4.1 Twinning Developed Countries with Developing
Countries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.4.2 Americas Silica Control Banding Effort . . . . . . . . . . . . . . . . . .
8.4.3 Expanding to an ORM Toolbox . . . . . . . . . . . . . . . . . . . . . . . . .
8.4.4 Fitting Control Banding into Occupational Safety and
Health Management Systems . . . . . . . . . . . . . . . . . . . . . . . . . .
8.4.5 Control Banding Compatibility with the Globally
Harmonized System for Classification and Labeling of
Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.5 Recognition of Specific Industries or Activities Where CB May
Be Adopted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.6 Additional Applications of CB in Ergonomics, Noise, and
Traumatic Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.6.1 Control Banding for Ergonomics . . . . . . . . . . . . . . . . . . . . . . . .
8.6.2 Control Banding for Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.6.3 Control Banding for Traumatic Injuries . . . . . . . . . . . . . . . . . .
8.6.4 Control Banding for Nanotechnology . . . . . . . . . . . . . . . . . . . .
53
54
55
56
57
57
58
58
59
59
60
60
61
61
61
62
62
63
65
66
66
67
67
68
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
Appendix A. Related Publications with Selected Annotations . . . . . . . . . . . . . . . . . . . 85
Appendix B. Allocation of Hazard Bands for Vapors . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
Appendix C. International Agreements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
xii
ABBREVIATIONS
ABPI
ACGIH
AIHA
ANSI
BAuA
BOHS
CB
CEFIC
CGS
CHIP
CIA
COSHH
CS
dB
DREAM
EASE
ECETOC
EMKG
EPA
EPL
EPS
ES&H
EU
GHS
GTZ
HCS
HSE
ICBW
ICCT
IH
ILO
INRS
IOHA
IPCS
ISO
ITG
KCT
KOSHA
LEV
LOAEL
MAK
MSDS
NIOSH
NOAEL
OEB
OEH
OEL
OHSAS
ORM
OSHA
PPE
ppm
PRIMAT
R-phrases
REACH
RSC
S-phrase
SME
SOBANE
SQRA
TLV
TWA
U.K.
WHO
WHOCC
WIND
WISE
xiv
GLOSSARY
control banding (CB): A strategy that groups workplace risks into control categories or
bands based on combinations of hazard and exposure information. The following four
main CBs have been developed for exposure to chemicals by inhalation:
Band 1: Use good industrial hygiene (IH) practice and general ventilation.
Band 2: Use local exhaust ventilation.
Band 3: Enclose the process.
Band 4: Seek expert advice.
This qualitative strategy to assess and manage risk focuses resources on exposure
controls and describes how strictly a risk needs to be managed.
COSHH Essentials: A CB strategy developed by the British Health and Safety Executive
(HSE) to assist small- and medium-sized enterprises in complying with Control
of Substances Hazardous to Health (COSHH) regulations. The COSHH Essentials
guidance is available in both a published document and in a Web-based model known
as eCOSHH Essentials [www.coshh-essentials.org.uk].
KjemiRisk: Assessment of chemical health risk based on experience and practice in the
Norwegian oil industry.
Occupational Risk Management (ORM): The process of using a combination of
knowledge, training, and resources of IH practice to address hazards in the workplace.
This process may encompass the use of a variety of toolbox strategies, which are defined
below, (and within these, toolkits), including qualitative risk assessment and controlfocused strategies to minimize hazardous exposures.
Toolbox: A collection of strategies for the control of worker exposures and may be
comprised of multiple toolkits. The toolbox concept is presented as a receptacle of
various toolkits used to address various workplace hazards associated with specific
industries and tasks. As such, the toolbox provides a mechanism for managing
occupational risk and is currently referenced as an ORM or CB toolbox. Toolboxes with
relevance for ORM in the United States include the broad (Environmental Safety and
Health Toolbox), the industry-specific (Construction Toolbox), and the occupationspecific (Hair Dressers Toolbox).
Toolkit: A narrowly defined, solutions-based strategy for the control of worker
exposures that is focused to a discrete task or series of tasks.
xv
ACKNOWLEDGMENTS
This document was developed by the Education and Information Division (EID), Paul
Schulte,Ph.D., Director. Thomas Lentz, Ph.D., was the project officer for this document,
assisted in great part by Richard Niemeier, Ph.D., and Charles Geraci, Ph.D. The basis
for this document was a report contracted by NIOSH and prepared by Deborah Imel
Nelson, Ph.D. (University of Colorado, Boulder) and David M. Zalk (Lawrence Livermore
National Laboratory). The following persons and organizations were especially helpful
in providing information for the initial report: Jennifer Silk (OSHA, retired), Andrew
Garrod (HSE), Paul Evans (HSE), the National Control Banding Workshop Organizing
Committee, and the Risk Assessment Committee of the American Industrial Hygiene
Association.
For review and contributions to the technical content of this document, the authors
gratefully acknowledge the following NIOSH personnel:
Education and Information Division
Catherine Beaucham
Donna Heidel
Alan Weinrich
Ralph Zumwalde
xvi
The authors thank Jane Weber, Sue Afanuh, Anne Hamilton, Elizabeth Fryer, Vanessa
Becks, Gino Fazio, and Jackie Rogers for their editorial support and contributions to
the design and layout of this document. Clerical and information resources support in
preparing this document was provided by Lucy Schoolfield, Norma Helton, Rosmarie
Hagedorn, and Laurel Jones.
Finally, special appreciation is expressed to the following individuals for serving as
independent, external reviewers and providing comments that contributed to the
development or improvement of this document:
Anne Bracker, University of Connecticut Health Center, Farmington, Connecticut
Patrick Breysse, Ph.D., School of Public Health, Johns Hopkins University,
Baltimore, Maryland
Warren Brown, American Society of Safety Engineers, Des Plaines, Illinois
Alberto Camacho, Ph.D., Deutsche Gesellschaft fr Technische Zusammenarbeit
(GTZ) GmbH, Germany
Paul Evans, Health and Safety Executive, Bootle, United Kingdom
Ho Sweet Far, Ph.D., Ministry of Manpower, Singapore
Henri Heussen, Ph.D., Arbo Unie Expert Centre for Chemical Risk Management,
the Netherlands
Paul Hewett, Ph.D., EAS Solutions, Inc., Morgantown, West Virginia
Walter Jones, Laborers Health and Safety Fund of North America,
Washington, DC
Byung Gyu Kim, Korea Occupational Safety and Health Agency, Republic of Korea
Jacques Malchaire, Universit catholique de Louvain, Belgium
Rolf Packroff, Ph.D., Federal Institute for Occupational Safety and Health,
Dortmund, Germany
Carolyn Vickers, World Health Organization, Geneva, Switzerland
Dee Woodhull, ORC Worldwide, Washington, DC
xvii
1
Challenges of Traditional Risk Management Using
Occupational Exposure Limits
The traditional approach to protecting
worker health was pioneered in the late
19th century when the first occupational
exposure limits (OELs) were established
in Germany [Jayjock et al. 2000]. Sampling and analysis of airborne contaminants was performed, and results were
compared with OELs. In 1946 the American Conference of Governmental Industrial Hygienists (ACGIH) published its
first list of exposure limits for 148 chemicals, then referred to as Maximum Allowable Concentrations and renamed to
Threshold Limit Values (TLVs) in 1956
[ACGIH 2007]. In the following decades,
this sampling-and-analysis approach to
risk management was adopted by many
of the industrialized nations and, as a result, contributed to the improvement of
working conditions, increased span and
quality of life for workers, and decreased
compensation costs. As a case in point, for
the years 1972 and 2000, records from the
U.S. Department of Labor, Bureau of Labor Statistics, indicate a reduction in occupational injuries and illnesses per 100
workers from 10.9 cases to 6.1 [Swuste and
Hale 1994; NIOSH 2002, 2004]. However,
the proportion of injuries and illnesses related to chemical hazards is not known.
Strict reliance upon sampling and analyzing airborne contaminants and comparing results with OELs has become increasingly difficult in recent decades because of
the growing number of hazardous chemicals. The increasing number far outweighs
the ability and resourcesof government
and other agencies external to chemical
manufacturersto determine associated
OELs. To address this concern, the European Commission promulgated regulations known as the Registration, Evaluation, Authorisation and Restriction of
Chemicals (REACH), which would shift
the burden of proof of chemical safety to
manufacturers and would apply to most
chemicals in commerce [EC 2001].
Also contributing to the increasing difficulty
to protect worker health is the large variability in exposure measurements, both within
and between workers. Because of these
challenges, individual companies, trade associations, and government agencies have
developed innovative strategies to protect
both worker health and the environment.
2
Problems Implementing Measures to Limit
Workplace Exposures
To control workplace exposures to hazardous chemicals, in the late 1980s the
United Kingdom Health and Safety Executive (HSE) developed a simplified strategy to assess health risks in the workplace
called Control of Substances Hazardous
to Health (COSHH). Despite much optimism that these regulations would bring
greater emphasis on the assessment of
risks to health in industry [Parker 1989],
their effective implementation met many
challenges [Winterbottom 1987]. An unpublished survey of 2,000 companies,
taken shortly after COSHH promulgation, showed widespread ignorance of
the new regulations and their implications
among smaller concerns [Seaton 1989].
Through the 1990s, there were many reports of deficiencies and needs of many
workplaces in complying with COSHH
regulations, particularly in healthcare settings [Hutt 1994; Menzies 1995; Fraise
1999; Barker and Abdelatti 1997; Cooke
et al. 1991; Harrison 1991; Waldron 1989;
Aw 1989].
In an effort to understand better the problems with implementation of COSHH,
HSE conducted market research to characterize industrys perception of OELs
and the degree to which decisions on control measures were affected by OELs [Topping et al. 1998; Tischer 2001b]. Telephone
interviews were conducted about chemical use, sources of information, risk management, and understanding of COSHH
and OELs among 1,000 randomly selected
chemical users and 150 safety and health
representatives of trade unions. The majority (75%) of respondents worked at
facilities with fewer than 10 full-time
workers, mirroring the makeup of British
industry, although the majority of trade
union representatives worked at companies employing more than 100 workers.
The findings follow:
Decisions on control measures were
based largely on information from
suppliers and on personal experience.
Most respondents took measures
to protect workers, primarily by
making personal protective equipment (PPE) available, followed by
process controls. This finding indicates that failure to comply results more from lack of knowledge
than from unwillingness to meet
the requirements.
Only 35% of the respondents were
aware of COSHH; only 19% truly
understood OELs.
Trade union representatives tended to have greater understanding
3
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
3
The Origins of Control Banding for Chemical Agents
In the late 1990s the advancements made
since the 1970s in risk and control strategies were combined to result in a simple
but powerful concept:
Health Hazard + Exposure Potential Generic
Risk Assessment Control Strategy
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Table 1. Key elements in the evolution of qualitative occupational risk management and
CB* concepts and their references in the literature
Element(s)
References
HMSO 1988
Application of safety risk concepts to workplace health (in laboratories): (1) categorization of hazard using R-phrases, (2) simple strategy to estimate exposure in laboratories or a workplace risk matrix
using both to identify appropriate control solutions
Use of hazard ratings (e.g., for prioritizing IH monitoring, installing Henry and Schaper 1990
engineering controls, selecting PPE)
Relationship between risk phrases (R-phrases) and OELs
Use of carcinogenic ranking of aromatic amines and nitro compounds to suggest practical workplace controls
Application of the RSC strategy beyond laboratories (e.g., the phar- Naumann et al. 1996; Money
maceutical industry); these strategies use R-phrases and simple algo- 1992a; CIA 1993
rithms to estimate exposures and combine both to suggest controls,
representing the first use of CB concepts for wider use in industry
[Money 2003]. These sector-specific strategies led to the idea that
hazard classification could provide a basis for generic exposure
control standards [Money 2003] and went beyond original categorization of carcinogens to include other toxic endpoints (e.g., CIA
[1993]). (Note: Strategies used in the pharmaceutical industry now
include lacrymators, highly toxic substances, reproductive hazards,
irritants, sensitizers, and mutagens [Tait 2004].)
Application for specific product classes and families, allowing more
detail in a more limited setting (ranking of carcinogens and linking
with facility design and safe handling guidelines)
Health risk assessment for product classes and families. The CIA
[1993] includes a table for colorants that includes hazard category
(14), hazard classification (e.g., toxic, corrosive), associated Rphrase, guideline control level (8-hour TWA), and a separate set of
recommendations for each hazard category.
(Continued)
Table 1 (Continued). Key elements in the evolution of qualitative occupational risk management and CB* concepts and their references in the literature
Element(s)
References
ABPI 1995
RSC 2003
Safety, health, and environmental risk assessment for users of chemi- UIC 1999
cals
Strategies for the tiered and targeted risk assessment of chemicals
ECETOC 2002
ECETOC 2002
ECETOC 2002
IH=industrial hygiene
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Suppliers
Assign risk phrase (R-phrase) (see
Section 3.2.3) or other toxicologic
rating to a substance.
Assign R-phrase to appropriate hazard band (see Table 4).
Report R-phrase on safety data sheets.
Consider hazard statements of the
Globally Harmonized System for
Classification and Labeling (GHS)
of chemicals.
Determine boiling point for liquid
substances and preparations.
Establish better terms to discriminate low, medium, and high potential exposures for airborne particulates.
Users
Acquire complete understanding
of the strategy, including R-phrases, quantity of substance in use, and
dustiness/volatility of substance.
Construct strategy to combine
quantity in use, dustiness/volatility,
and other determinants, to predict
exposure band.
The hazard posed by exposure to a chemical via a given route was ranked according
to the chemicals European Union (EU)
risk phrases (R-phrases), and potential for
exposure was estimated by the quantity in
use and the volatility of liquids or, for solids, potential for airborne particulates.
Gardner and Oldershaw [1991] presented a comparison of the American (ACGIH TLVs) and German OELs to the
designated R-phrases for volatile organic
substances [EEC 1987]. They found (1)
that the distributions of the OELs for
substances consistent with grouping by
R-phrase 23 (toxic by inhalation) and Rphrase 26 (very toxic by inhalation) best
fit a log-normal distribution and (2) that
the means for both R-phrase groups were
not significantly different. They concluded that the R-phrases, though not OELs,
could be referenced as Pragmatic Exposure-Control Concentrations and applied
as guides to control inhalation exposure
when other information was lacking. The
authors suggested that such CB would be
useful in cases where toxicologic data on
substances were incomplete or the ability
to understand such data was limited.
3.2.3 R-Phrases
In 1998 the Annals of Occupational Hygiene published a series of papers outlining a CB strategy in which the hazard categorization, or hazard band, was combined
with the potential exposure to determine
a recommended level of control strategy.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Figure 1. The CEFIC exposure management system. Source: Money 2003 (with permission
from Oxford University Press, British Occupational Hygiene Society, and the author).
10
Figure 2. Key elements of the ECETOC strategy for the tiered and targeted risk assessment
of chemicals. Source: Money 2003 (with permission from Oxford University Press, British Occupational Hygiene Society, and the author).
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Health Hazard
Substances allocated to a
hazard band using R-phrases
Exposure Potential
Substances allocated to dustiness or volatility band and a
band for the scale of use
Control Approach
Type of approach needed to
achieve adequate control
COSHH Essentials is the most fully developed CB strategy for chemical assessment, and guides users in selecting the
appropriate level of management based on
the following:
The type of task being performed
(12 general levels)
The assignment of the chemical
substance to Hazard Band AE (see
Section 4.4 and Table 4), based on
its hazard
The volatility (3 levels) or potential for generation of airborne particulate (3 levels) of the chemical
substance
The quantity of the chemical substance used in the task (3 levels)
Control Approach 3Containment. Containment or enclosure, allowing for limited, small scale breaches of containments.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Murray State and Eastern Kentucky Universities, and local businesses in the Commonwealth of Kentucky [AIHA 2007].
Within the GTZ Chemical Management
Guide, the first of three steps is to identify
hot spots in a companys manufacturing
processes (e.g., places where inefficient
storage, handling, use, and disposal can be
observed). Preparing a detailed chemical
inventory is the second step. The last step
is use of one or more of the following resources: basic risk assessment, description
of control strategies, MSDSs, safety phrases for hazardous substances, and symbols
for labeling hazardous substances. This
strategy has been ground-tested in Indonesia and proved successful. Although CB
may be too sophisticated for many small
enterprises, field observations suggest that
since the medium and larger enterprises
have more MSDSs on site, they have a
greater potential for conducting risk assessments using the International Labor
Office (ILO) Chemical Control Toolkit
(ICCT) [Tischer and Scholaen 2003].
Since 2005, another effort in Germany
led by the German Bundesanstalt fr Arbeitsschutz und Arbeitsmedizin (BAuA)
has offered an easy-to-use workplace
control scheme for hazardous substances
(EMKG) as practical guidance for workplace risk assessment in SMEs [Packroff et
al. 2006]. Applying information obtained
from MSDSs to basic workplace conditions, the user of EMKG can derive control strategies to minimize exposure via
inhalation or skin contact.
EMKG is similar to COSHH Essentials.
The main differences between the two are
some divergent allocations of R-phrases to
hazard bands [German FMLS 2008] and
a more detailed tool to assess dermal exposure [German FMLS 2006]. CGSs for
typical tasks give guidance on precise
control measures within the control strategy determined with the generic tool. In
2007 the generic control guidance sheets
were supplemented with specific sheets
for activities with chemicals in the rubber
industry. Currently 36 CGSs offered on
BAuAs Web page are consistent with the
analagous topics in COSHH Essentials.
The EMKG offers nonregulatory guidance, but, like COSHH Essentials, is well
supported by legal obligations and Codes
of Practice from the tripartite Hazardous Substances Committee in Germany.
In May 2008 an enhanced version ofthe
scheme (EMKG 2.0) was launched on the
BAuA Web site [Kahl et al. 2008]. EMKG
2.0 includes 300 additional substances
with legal OELs in Germany. Users of the
scheme begin the risk assessment with the
OEL, which is aligned with a corresponding hazard band. Two possible practical
implementations of the scheme are (1) to
use the hazard group that directly relates
to the target airborne concentration range
that covers the OEL or (2) to use the hazard band below the OEL and the corresponding control strategy. In the first case
the employer has to improve the observance of the OEL by applying workplace
measurements, and in the second case the
employer can waive workplace measurements.
The expansion of EMKG 2.0 to substances
with OELs makes it adaptable for additional applications.EMKG can be used as
a simple tool to derive exposure scenarios
for substances to be registrated under the
REACH regulation by using the derived no
effect level, which is the REACH surrogate
15
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
a risk inventory, obtaining a plan for control measures, making instruction sheets
for the workplace, and helping to store
chemicals according to guidelines. For
the risk inventory, the employer uses Rphrases categorized according to COSHH
Essentials. Then the employer completes
a qualitative exposure assessment by responding to questions to determine the
chemicals exposure class. The tool automatically calculates a risk score to complete the initial assessment of the health
risk. The employer reviews the selection
of various control measures based on the
risk score, and chooses the most appropriate and effective one accordingly [Tijssen
et al. 2004]. Stoffenmanager is currently
generic, but the Dutch have plans to adapt
it to fit into various industry sectors at a
later date. Industry sector-specific tools
would be very helpful and enhance its use
[Tijssen et al. 2004].
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
stage are examined in more detail. Workers and management are assisted through
the observation process by a nine-page
guide. In analysis, if the problems remain
after the first two stages, an occupational
health practitioner carries out appropriate measurements to develop proper solutions. An expert is called in for the final
stage to design a more sophisticated solution or improve an existing one.
a need to implement and maintain controls, review the assessment every 3 years,
and determine if training and personal air
monitoring are necessary. The third control strategy for the ICCT (containment)
is comparable with the SQRA level 4 (high
risk), suggesting implementation of engineering controls, personal air monitoring and training, PPE requirements, and
reassessment of risk after all controls are
put into place. The ICCT fourth control
strategy (special circumstances) aligns
with the SQRA level 5 (very high risk),
which directs users to consult specialists
for advice, to comply with requirements
for risk level 4, and reassess after controls
are implemented.
In the theoretical comparison of the CB
strategies, risk is calculated using variables
of vapor pressure or particle size, ratio of
the odor threshold to the applicable OEL,
amount of chemical used and duration
of work per week, and control measures.
This result is then compared with the control strategy determined by the ICCT, given a direct evaluation of the consistency
of the models because the ICCT does not
take into account existing hazard control
measures. To assess against the Toolkits
control strategy, the empirical comparison of the models uses actual personal air
monitoring data that the SQRA methods
risk level was based on. Selected processes
at 27 SMEs received this comparison. The
processes included metal working, paint
manufacturing, chemical processing,
printing, dry cleaning, and electronics
industries. The results of the theoretical
comparison indicate that the Toolkit and
the SQRA method are somewhat consistent with a difference between the control
strategy and risk level being one to two
19
4
The Architecture on Which Control Banding is Based
The concept of CB grew out of the qualitative and semi-quantitative approaches
that have been practiced as a complement
to the traditional model of air sampling
and analysis.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Category X
(Special considerations)
OEB A
OEB B
OEB C
This rating system is opposite that used in the COSHH Essentials rating.
kg body weight
Table 3. OEB* and corresponding concentrations for gases and vapors (ppm)
and dust (mg/m3)
Category X
OEB A
OEB B
OEB C
OEB D
Dusts (mg/m3)
Special considerations
<0.5
0.55
550
50500
<0.1
0.11
110
Not applicable
22
1995]. Thus the level of exposure recommended varies with the stage of product
development and toxicity testing.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Essentials and (2) it compared these assignments with health-based OELs. Each
hazard band, which is based on toxicologic considerations, covers a log (10-fold)
concentration range. Because the relationship between the ppm (parts per million)
concentration and the mg/m3 concentration of a vapor is a function of its molecular weight (and also temperature and pressure, though not discussed in this article),
the working group that oversaw development of this chemical classification decided to adopt a pragmatic strategy and to
align the exposure bands as seen in Table
4. However, it must be noted that due to
this alignment, in mg/m3 terms, the concentration range for substances in vapor
form is substantially higher than that for
the substance in particulate form, for the
same toxicologic hazard band.
In general, allocation of substances into
hazard bands is influenced by presence of
an identifiable dose threshold, seriousness
of the resultant health effect, and relative
exposure level at which toxic effects occur.
If a substance has more than one R-phrase,
the R-phrase leading to the highest level
of control governs. See Appendix B for a
more detailed explanation of allocation of
vapors to hazard bands.
To evaluate COSHH Essentials, the Rphrases and resulting target airborne concentrations and the relevant health-based
OELs were compared (U.K. and German
MAK [Maximale Arbeitsplatzkonzentration (maximum concentration of a substance in the ambient air in the workplace)]
values). This comparison was conducted
for 111 substances with recent, scientificbased OELs from the U.K. and MAK and
with identifiable thresholds (thus excluding
25
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Hazard band
Target airborne
concentration range (Note 1)
Risk phrases
R36, R38, all particulates and vapors not allocated to another band
(Note 2)
R20/21/22, R40/20/21/22
R48/23/24/25, R26/27/28,
R39/26/27/28, R40 Carc. Cat. 3,
R60, R61, R62, R63
Prevention or reduction of
skin and/or eye exposure
Note: COSHH (Control of Substances Hazardous to Health) Essentials is regularly reviewed to reflect any
changes to risk phrases.
Source: Brooke 1998
[1998] stresses that the process is not intended as a replacement for the healthbased OEL-setting process.
Concerns have been raised about the accuracy of the EU classification of chemical
substances [Ruden and Hansson 2003].
In a comparison of EU classifications for
acute oral toxicity for 992 substances with
those available in the Registry of Toxic Effects of Chemical Substances, Ruden and
Hansson found that 15% were assigned
too low a danger class and 8% too high.
They were unable to determine the cause
because of insufficient transparency of the
process. It should be noted that Registry
of Toxic Effects of Chemical Substances is
Table 5. Overall results for comparison of COSHH* Essentials hazard bands with
health-based OELs, using all hazard bands
Dusts
Vapors
Total
Number of substances
33
78
111
14 (42%)
44 (56%)
58 (52%)
Number for which OEL is higher than target airborne concentration range of hazard band
19 (58%)
32 (41%)
51 (46%)
Number for which OEL is lower than target airborne concentration range of hazard band
0 (0%)
2 (3%)
2 (2%)
33 (100%)
76 (97%)
109 (98%)
should, as far as possible, be appropriate to ensure that the hazardous properties of a substance are not expressed.
Equally important and essential to the
successful implementation of CB strategies is the effort to standardize the categorization of hazards, a primary objective of
the global harmonization initiative discussed in a later section.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Description
Gram quantities of medium/low dusty material
Gram quantities of high dusty material; kilogram/ton quantities of low
dusty material
Kilogram quantities of medium/high dusty materials
Ton quantities of medium/high dusty material
28
Description
EPL1
EPL2
EPL3
EPL4
EPS4
>10
110
0.11
EPS3
EPS2
110
0.11
0.010.1
0.11
0.010.1
0.0010.01
EPS1
0.010.1
0.0010.01
<0.001
EPL4
EPL3
EPL2
EPL1
CS1
CS2
CS3
>500
50500
550
50500
550
0.55
550
0.55
0.050.5
<5
<0.5
<0.05
29
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Exposure bandliquid
(ppm*)
Hazard band
>500
50500
550
0.55
0.050.5
<0.05
Not recommended
A
B
C
D
E
>10
110
0.11
0.010.1
0.0010.01
<0.001
Source: Maidment 1998
*ppm=parts per million
5. Substitute hazard band for exposure potential and invert strategy to produce control predictive strategy. This produces an
empirical model that can be used
to predict the appropriate CS to
achieve adequate control based on
the hazard and the exposure bands
(Tables 11 and 12).
In applying this strategy for truly short exposures (i.e., <30 minutes), the CS could be
dropped by one level (e.g., from CS2 to CS1).
Even though this last strategy leans heavily
on the work of previous models and strategies, it has a number of unique features,
including an electronic version accessible
via the Internet. In addition, it theoretically meets all six of Moneys [2003] core
principles: understandability, availability,
practicality, user-friendliness, confidence
on the part of users, and transparent, consistent output. Despite its attributes, validation and verification remain important
requirements. Oldershaw [2003] has cautioned that the COSHH Essentials strategy
could not be adopted uncritically by other
countries; further, the strategy must be
30
Table 11. Prediction of CS* from hazard band and exposure potential (solids)
Hazard band
EPS4
EPS3
EPS2
EPS1
A
B
C
D
E
CS2
CS3
Special
Special
Special
CS1
CS2
CS3
Special
Special
CS1
CS1
CS2
CS3
Special
CS1
CS1
CS1
CS2
Special
Table 12. Prediction of CS* from hazard band and exposure potential
band for liquids
Hazard band
A
B
C
D
E
EPL4
EPL3
EPL2
EPL1
CS2
CS2
CS3
Special
Special
CS1
CS2
CS3
Special
Special
CS1
CS1
CS2
CS3
Special
CS1
CS1
CS1
CS2
Special
31
5
Validation and Verification of Control Banding
Strategies
A significant issue for the implementation
of CB is the accuracy of the decision logic.
Underprescription of control could lead
to serious illness, even death, and overprescription could lead to unnecessary expense. Future identification of either case
could lead to a loss of confidence in the
system as a whole. Assurance can be provided by validation. Each step of the CB
strategy may be validated independently
of the others.
required, generally around 20 measurements on each of 10 workers when establishing the average and range. If it is
considered necessary to focus on the top
5% or 10% of exposures, then larger numbers may be required, or perhaps a model
can be introduced to evaluate the extreme
range of the potentially log-normal distribution.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
5.1.4 Training
A goal of CB is to provide a system that
can be used by nonexperts in the field of
IH practice, so training in the use of the
methodology is an essential part of many
CB strategies. Training programs should
be evaluated with respect to the following: target (e.g., was the training provided
to those with authority to recommend
or make changes?), reception (e.g., was
the training offered sufficiently often, by
a source considered trustworthy, in an
environment conducive to processing?),
and outcome (e.g., was the training implemented, and was the system used in the
correct manner?). Evaluation of training
effectiveness is an important step to provide feedback addressing these and other
relevant questions.
Topping [2002a] responded that these arguments ignored the range of competencies in the workplace, and the number of
firms handling chemicals. He stated that
COSHH Essentials is not intended to replace monitoring but rather to provide
needed help to SMEs, pointing out that
the cost of conducting the extensive monitoring suggested by Kromhout would be
astronomical and that the capacity to
do so does not exist. He allowed that the
COSHH Essentials were designed to err
on the side of caution, that the strategy
had been peer reviewed by the British
Occupational Hygiene Society (BOHS),
and that there had been no complaints
about the recommended controls being
too stringent. Kromhout [2002b] replied
that he and the editor of Annals of Occupational Hygiene questioned the role of
tools like COSHH Essentials in contributing to a collapse of full time training
of occupational hygiene professionals in
Britain through lack of demand for expertise. Kromhouts strongest criticism
was that COSHH Essentials and EASE
had not been properly evaluated prior to
release and that BOHS review could not
replace the rigorous evaluation of testing
for reproducibility and validity. He recommended that COSHH and EASE be
used in the initial screening process.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
was considered to be a problem that requires additional attention. Scale of use was
judged to be straightforward. (Most of the
available data corresponded to the medium
scale of use, with very little in the milliliter or ton ranges.) Based on data available
(i.e., 958 data points732 for liquids and
226 for solids), the researchers limited their
analyses to scenarios in which the CS could
be determined from the historical reports,
assigning one of the four CSs.
Comparisons indicated that most of the
measured exposures fell within the predicted ranges. The 95th percentile of data
from different operations fit within the
ranges predicted by the COSHH Essentials model [Balsat et al. 2003; Tischer
2001b]. Exceptions were noted where
some of the limited data points were
above the predicted range: activities associated with carpentry workshops and application of adhesives, both of which represent small-scale, dispersive operations;
and handling of powdery substances in
kilogram quantities under local exhaust
ventilation (LEV).
Tischer et al. [2003] note that limited data,
representing a limited number of possible combinations of Exposure Predictor
Bands and CSs, were available for evaluation. In particular their data lacked description of scenarios involving the handling of milliliter or ton quantities of low
or high volatility/dustiness substances.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
that for CB strategies like COSHH Essentials, exposure bands do not always provide adequate margins of safety, there is
a high rate of under-control errors, they
work better with particulates than with
vapors, an inherent inaccuracy in estimating variability exists, and outcomes of this
model, taken together, may lead to potentially inappropriate workplace confidence
in chemical exposure reduction. With the
accuracy of the toxicologic ratings and
hazard band classification currently in
question, the proper reevaluation of exposure bands will be of great benefit to the
reliability of existing and future CB models. The authors also suggest that a more
40
6
Specific Issues in Control Banding
Most CB strategies are limited to the inhalation route of exposure and to certain
chemicals used in manufacturing (others
being regulated in specific statutes). Work
is ongoing to expand applications to other
topics, including dermal hazards, processgenerated hazards such as airborne crystalline silica, asthmagens, and asbestos.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
2 Higher skin
hazard group
Advice
Dust: 50 mg
Liquid: 1 mg
3 Highest skin
hazard group
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
44
7
Special Events Surrounding Control Banding
CB is currently the subject of much interest, both nationally and internationally.
International workshops have been held
in London (2002), Cincinnati (2004),
concurrently in Pilanesburg, South Africa and Orlando (2005), and South Korea
(2008). International collaborative agreements have been forged to coordinate the
work of international agencies and their
partners, and a global implementation
strategy has been developed.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
7.5 International
Agreements
ILO and WHO agreed to work together
under the auspices of the IPCS on January
23, 2003. The roles of each organization
were spelled out in the agreement [Vickers and Fingerhut 2002].
The Global Implementation Strategy for
the Occupational Risk Management Toolbox was outlined by the ITG at ICBW2
and approved on May 28, 2004. This
strategy, which discusses partners, stakeholders, the ICCT, key elements, terms of
reference, and the international research
agenda, can be found in Appendix C.
47
8
Critical Analysis of Control Banding Strategies
The core of this review is a discussion of the
strengths and weaknesses of CB strategies.
Much of the literature on these characteristics describes concepts and misperceptions
about CB and its potential applications,
similarities to other occupational safety
and health interventions, potential conflict
with OEL development, and the need for
environmental sampling and IH expertise.
This section also contains a critical analysis
of the barriers and catalysts for implementing CB in the United States. In addition,
consideration is given to the areas where
expansion of CB concepts or development
of new control-focused solutions and guidance might be explored.
In the broadest scope, the CB strategies and
related guidance for addressing occupational hazards are recognized for their potential to facilitate occupational safety and
health knowledge management. Knowledge management is an emerging field focusing on assessing the creation, transfer,
and use of knowledge to address specific
challenges [Schulte et al. 2004]. Effective
knowledge management can be accomplished through the development of guidance materials for hazard control and the
application of CB strategies.
8.1 A Discussion of
Weaknesses and
Strengths of CB Efforts
In evaluating the weaknesses and strengths of
the CB strategy, it is useful to refer to an outline of common issues, as shown in Table 14.
49
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Table 14. Issues relating to the strengths and weaknesses of the CB* strategy
CB Strategy Issues
Weakness summary
Strength summary
General CB vs.
COSHH Essentials
Implementation of CB strategies
will reduce the need for IH consultants and move profession toward
ES&H generalists.
CB vs. reliance on
OELs
CB strategies will not serve as a replacement for OELs in the United States. CB
validation protocol will include personal monitoring for OEL use.
COSHH Essentials criticisms are assisting in perfecting the strategy. Taskbased point source models do not require exposure prediction.
*CB=control banding
IH=industrial hygiene
50
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
concept relies on the goodwill of nontechnical overseers, who are likely to be undertrained and ill-equipped with appropriate
information to validate and maintain the
best controls [Tischer and Scholaen 2003;
Maidment 1998].
A limitation of the current CB strategy is
that it is static, whereas a system that is
reviewed and updated periodically would
ensure that the controls implemented and
the managerial oversight are maintained
over time. Consequently, part of validation is comparison among the possible
methods of implementing controls and
the construct within which these methods
are introducedto employers and workers. The validation effort supports development of task-specific guidance that integrally involves CB strategies in effective
control solutions.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
It is impossible to discuss any new system that seeks to protect workers in the
United States without addressing legal
considerations. One challenge relates to
implementing a generic CB system that
may provide practical tools for managing
and reducing hazardous exposures, yet
may not be applicable or provide appropriate protection in all cases [Jones and
Nicas 2004, 2006b; Money 2003; Kromhout 2002b]. It is essential to recognize
these limitations and to address information gaps to ensure that use of CB strategies
achieve the appropriate levels of workplace
protection, rather than contribute to occupational illness and injury, as well as to
employer liability.
harmonized strategy for classifying mixtures of these chemicals. The United Nations adopted the GHS strategy in 2003.
The United States, the European Union,
Canada, and many other countries are
now considering its use. In the United
States, four agencies have primary responsibility for its implementationConsumer Product Safety Commission (CPSC),
Department of Transportation (DOT),
Environmental Protection Agency (EPA),
and Occupational Safety and Health Administration (OSHA). OSHA has proposed rulemaking activity (first published
as a draft in 2005, with an update expected
in 2009) for revising its hazard communication standard to incorporate the GHS
elements. The revised hazard communication standard will require use of standard
hazard statements on U.S. labels as well as
on MSDSs.
Global implementation of the GHS would
provide an international system upon
which to base CB. In recognition of this,
the ILO has included the GHS hazard categories in its ICCT. Action is also being
taken to modify the roughly 1,600 International Chemical Safety Cards prepared
under the IPCS to follow the GHS criteria for classification and the harmonized
hazard statements for the most commonly
used chemicals.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Table 15. Current documented input to the ANSI* Z10 review committee for
pertinent sections
3.2 Employee participation (Identify tasks, risks, and possible controls)
no mention of evaluating exposures
5.4 Document and Record Control Process
if CB in an OHSAS, it becomes part of the process
6.1 Monitoring and Measurement: F. Other methods
does not rule out semi-quantitative/qualitative
6.3 System Audits: evaluating activities and corrective actionsrecordable CB
process fits audits
6.4 Track actions for effective implementation
possible weak point with CB, needs strengthening
*ANSI=American National Standards Institute
CB=control banding
applications are part of the decision matrix. Creating this system with a task force
of safety and health professionals working
in concert with managerial oversight and
workplace employee representatives will
facilitate the best use of CB to maximize
its effectiveness, consistent application,
and economic efficiency. An example of
a vehicle for this strategy is the American
National Standards Institute (ANSI) Z10
committee (Table 15). A major premise
on which a dynamic strategy should rely
is the understanding that industry specific, worker-influenced solutions have the
best possibility of being applied, achieving
success, remaining in place over time, and
having a mechanism for ensuring commensurate controls are in place regardless
of changes in tasks, processes, products,
and the inevitable workplace rotation of
affected worker populations.
56
8.3 Implementation of a
Risk Management
System in the United
States that Includes
CB Strategies
The implementation of CB strategies in
the United States for qualitative risk assessment and management requires additional
research and development. Topic areas for
further exploration include the provision
of national-level guidance and coordination, pilot projects at the state level, and
expansion of the ORM (Occupational Risk
Management) Toolbox to include more
chemicals and ergonomic, safety, and environmental concerns. Cooperation with
international efforts to implement CB can
strengthen efforts in the United States
through bilateral sharing of research and
experience. Linking CB strategies with Occupational Safety and Health Management
Systems and the GHS will add value.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
within selected industrial sectors and specific trades. One objective of the validation process would be to emphasize field
IH input for identifying needs for improving toolkits and determining the scope of
their implementation. This working group
will decide which measurable parameters
for ranking hazards to consider in choosing the appropriate CB, the prioritization
of controls, and the effectiveness of their
application. Because personal sampling
requirements are essential to validation
of the CB strategy, the validation strategy
should be developed using statistically
supported bases and be coordinated with
research that focuses on prospective and
retrospective epidemiologic studies. Validation efforts should simultaneously compare and contrast the success rates of different methods of implementing a given
CB strategy.
both workers and employers in its development [Money 2003]. This strategy
fits well with the intent of the OSHA Alliance Program created in 2002 to enable
organizations committed to safety and
health to work cooperatively with OSHA
to prevent illnesses, injuries, and fatalities
in the workplace. Seeking and providing
end-user input as part of this focus on
the workforce will help improve the final
CB product and determine when its use
is most practical and how best to implement it.
could be developed, validated, and implemented prior to creation of a parallel chemical-agents strategy. For applications in
this arena, the CB strategy could promote
the use of practical tools for assessing and
reducing risk based on recent advances
in participatory ergonomics. Compiling
a repository of well-researched, validated, existing work practices in the United
States could lead to a solutions database
for musculoskeletal hazards and ergonomic control options. Initial discussions
of expanding CB strategies to include ergonomics were first raised at the ICBW2,
and subsequently the International Ergonomics Association has become involved
through participation at both the ICBW3
and ICBW4.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
the air, soil, wastewater, and waste disposal streams. It is essential to involve stakeholders to define minimum performance
standards, and to include this input in the
creation of simplified training programs.
For implementation in the United States
and other countries, it would be progressive to incorporate pictorial training consistent with the GHS symbology to reduce
the need for multiple translations. A challenge facing industrial hygienists in communicating exposure reduction successes
is the dearth of appropriate yardsticks for
measuring program benefits of a disease
prevented. Possible solutions to address this
challenge include better surveillance and
use of appropriate metrics to track the effectiveness of hazard control interventions.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
guidance and coordination of pilot projects at the state level. An ORM Toolbox
concept has become a byproduct of this
coordination, which has broadened the
CB model to include a more comprehensive exposure control basis for universal
industries such as construction and agriculture. Working to further develop this
multidisciplinary effort is an international, informal working group that includes
the United States, United Kingdom, and
the Netherlands that is seeking occupational health and safety professional input
toward the development of a task-specific
Construction Toolbox framework [Zalk
2008; van Thienen and Spee 2008].
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
69
9
Discussion and Conclusions
CB strategies can be used effectively for
performing workplace risk assessments
and implementing control solutions for
many, but not all, occupational hazards.
COSHH Essentials is a popular toolkit
model that has been well researchedalthough further validation is important
with narrowed applications in the larger
scale of CB. CB strategies will not eliminate the need for personal monitoring and
should lead to an increased appreciation
for the role of the IH professional and useful solutions-based databases.
A review of the literature and the brief
history of CB evolution, applications, and
evaluation indicates that CB strategies
cannot provide appropriate solutions for
the assessment and management of all occupational hazards. There are situations
in which CB cannot provide the precision
and accuracy necessary to protect worker
health; alternatively, there are undoubtedly situations in which CB will provide
a higher level of control than is necessary.
Despite these concerns, CB strategies have
the potential to be entry-level tools for occupational risk management. They can
be an integral part of a tiered strategy for
risk assessment, in which simpler tools
are used at a screening level, followed by a
more complex strategy as needed or as indicated by the particular situation [Nelson
et al. 2003; Mulhausen et al. 2004].
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
72
10
Recommendations to Facilitate the Implementation
of CB Strategies in the United States
Based on the potential utility of CB and the
fact that most chemical substances do not
have established OELs, it seems appropriate to explore applications and implementation of CB strategies in the United States.
These recommendations are made under
the categories of improving awareness of
concepts, validation considerations, expansion of the CB model, dissemination,
coordination, and collaboration. From the
review of the literature and of recent workshops (including the U.S. National Control
Banding Workshop in 2005), symposia,
and conferences exploring the utility and
potential applications of qualitative risk assessment and management (i.e., CB) strategies, the following recommendations have
been identified with potential activities and
programs to facilitate the implementation
of CB in the United States.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
74
10.3 Recommendations
for Expanding the
Control Banding Model
3. Validate each step of the CB strategy independently: exposure prediction, hazard prediction, control
recommendations, training, and
control implementation.
4. Assess errors associated with CB
hazard classification, exposure assessment, and control recommendations to determine the accuracy
of the model.
10.4 Recommendations
for Disseminating
Control Banding
1. Develop public sector (governmental) and private sector (trade
association, industry, organized
labor, academic consortia) strategies to coordinate efforts for developing, implementing, and evaluating qualitative risk assessment
and risk management strategies
and task-specific, hazard-control
guidance.
2. Create awareness, implementation, and dissemination strategies
among the regulatory, consultative, professional, and trade associations consistent with research
to practice concepts.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
76
References
ABPI [1995]. Guidance on setting in-house
occupational exposure limits for airborne
therapeutic substances and their intermediates. London: The Association of the
British Pharmaceutical Industry.
ACGIH [2007]. About/History [www.acgih.
org/about/history.htm].
journal L131
.
(14th individual Directive within the meaning of Article
16(1) of Directive 89/391/EEC), European
Commission, 5 May, pp. 1123 [http://eurlex.europa.eu/LexUriServ/LexUriServ.do?
uri=CELEX:31998L0024:EN:HTML].
77
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
offe/TRGS/TRGS-401.html__nnn=true]
(in German).
German FMLS [2008]. Federal Ministry for
Labour and Social Affairs, Code of Practice
TRGS 400, Workplace Risk Assessment for
workplace use of chemicals, Gemeinsames
Ministerialblatt der Bundesministerien,
11/12, [www.baua.de/de/Themen-von-AZ/-Gefahrstoffe/TRGS/TRGS-400.html__
nnn=true] (in German).
Goede HA, Tijssen SC, Schipper HJ, Warren
N, Oppl R, Kalberlah F, van Hemmen JJ
[2003]. Classification of dermal exposure
modifiers and assignment of values for a
risk assessment toolkit. Ann Occup Hyg
47(8):609618.
Guest I [1998]. The Chemical Industries Association guidance on allocating occupational exposure bands. Ann Occup Hyg
42(6):407411.
Harrison DI [1991]. Control of substances
hazardous to health [COSHH] regulations
and hospital infection. J Hosp Infect 18
Suppl A:530534.
Harrison J, Sepai O [2000]. Should control
measures be based on air measurements
or biological/biological effect monitoring?
Occup Med 50(1):6163.
Henneberger, PK, Kreiss K, Rosenman KD,
Reilly MJ, Chang YF, Geidenberger CA
[1999]. An evaluation of the incidence of
work-related asthma in the United States.
Int J Occup Environ Health 5(1):18.
Henry BJ, Schaper KL [1990]. PPGs safety
and health index system: a 10-year update
of an in-plant hazardous materials identification system and its relationship to finished product labeling, industrial hygiene,
and medical programs. Am Ind Hyg Assoc
J 51:475484.
HMSO [1988]. The control of substances hazardous to health regulations 1988 (Statutory Instrument 1657). London, England:
Her Majestys Stationery Office.
HSE [1999]. COSHH Essentialseasy steps
to control chemicals. Sudbury, England:
Health and Safety Executive.
References
Jackson H [2002]. Control BandingPractical tools for controlling exposure to chemicals. Asian-Pacific Newsletter 9:6263.
Jackson H, Vickers C [2003]. Report of the
International Control Banding Workshop,
London,England, November 2002 [www.
ioha.com/topics/control_banding/cbwupdate.pdf].
Jayjock MA, Lynch JR, Nelson DI [2000].
Risk assessment principles for the industrial hygienist. Fairfax, VA: AIHA Press.
Jones R, Nicas M [2004]. Evaluation of the
ILO Toolkit with regards to hazard classification and control effectiveness. Poster
presented at the Second International
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
References
Swuste P, Zalk DM [in press]. Control banding or barrier banding, a qualitative tool
for risk prevention. Am J Ind Med.
Tait K [2004]. Control banding: an improved
means of assessing and managing health
and safety risks at Pfizer. Presented at the
Second International Control Banding
Workshop, Cincinnati, OH, 1 and 2 March.
Tijssen S, le Feber M, Marquart H, Heussen H,
West J, Noy D [2004]. A new tool for small
and medium enterprises to work safely with
hazardous substances. Presented at the Second International Control Banding Workshop, Cincinnati, OH, 1 and 2 March.
Tischer M [2001a]. What does low exposure
mean? Exposure considerations in the testing of notified new substances. Appl Occup Environ Hyg 16(2):228232.
Tischer M [2001b]. Helping SMEs to manage risks from chemicals in the workplace.
Proceedings from an international workshop, 2627 November 2001, Amsterdam,
the Netherlands. Zeist: TNO Nutrition and
Food Research.
Tischer M [2002]. Current BAuA/GTZ research on occupational exposure and
control strategies: recent results from various industrial areas and from Indonesian
SMEs. Presented at the First International
Control Banding Workshop, London, England, 4 and 5 November.
Tischer M, Scholaen S [2003].
Chemical management and control strategies: experiences
from the GTZ pilot project on chemical
safety in Indonesian small- and medium-sized enterprises. Ann Occup Hyg
47(7):571575.
Tischer M, Bredendiek-Kamper S, Poppek U
[2003].
Evaluation of the HSE COSHH Essentials exposure predictive model on the
basis of BAuA field studies and existing
substances exposure data. Ann Occup Hyg
47(7):557569.
Topping MD [2001]. Occupational exposure
limits for chemicals. Occup Environ Med
58(2):138144.
81
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
documentairesHygiene et securite du
travail 179:2934.
Wagner G, Wegman D [1998]. Occupational
asthma: Prevention by definition. American J Ind Med 33:427429.
Waldron HA [1989]. COSHH and the NHS.
Br J Ind Med 46(11):753754.
Warren N, Goede HA, Tijssen SCHA, Oppl R,
Schipper HJ, van Hemmen JJ [2003].
Deriving default dermal exposure values for
use in a risk assessment toolkit for small
and medium-sized enterprises. Ann Occup Hyg 47(8):619627.
Winterbottom JE [1987]. The control of substances hazardous to health regulations: an
industrialists view of legislation. Ann Occup Hyg 31(1):8188.
Woodward KN, McDonald A, Joshi S [1991].
Ranking of chemicals for carcinogenic
potencya comparative study of 13 carcinogenic chemicals and an examination of
some of the issues involved. Carcinogenesis 12(6):10611066.
Yap SM [2004]. Assessing the utility of the ILO
Toolkit in Singapore. Presented at the Second International Control Banding Workshop, Cincinnati, OH, 1 and 2 March.
Zalk DM [2003]. Control banding principles
to reduce musculoskeletal disorders; the
ergonomics toolkit. Proceedings of the International Ergonomics Association Triennial Congress, Seoul, South Korea, 24-29
August, V5(327).
Zalk DM [2006]. Practical prevention in safety: from control banding to barrier banding. In Proceedings of the International
Working on Safety Conference. Eemhof,
the Netherlands, 15 September, 17(5).
Zalk DM [2008]. Barrier Banding and the Construction Toolbox. Proceedings of 4th International Control Banding Workshop at
XVIII World Congress on Safety and Health
at Work. Seoul, South Korea, 1 and 2 July.
Zalk DM, Nelson DI [2008]. History and evolution of control banding: a review. J Occup Environ Hyg. 5(5):33046.
References
Legislation/1967L0548EC.htm].
osha.europa.eu/en/good_practice/sector/construction/case_studies.stm].
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Nelson DI, Zalk DM [2004]. Control Banding: Wish Id thought of it myself! AIH
Diplomate 4(3): vvii.
Nighswonger T [2001]. How can Industrial
Hygienists position themselves for success? Occup Hazards 57:3095.
NIOSH [1999]. Identifying High-Risk Small
Business Industries, The Basis for Preventing Occupational, Injury, Illness, and Fatality. Cincinnati, OH: U.S. Deparatment
of Health and Human Services, Public
Health Service, Centers for Disease and
Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH)
Publication No. 99107.
Northage C, Marquart H [2001]. Occupational
exposure information needs for regulatory
risk assessment of existing chemicals. App
Occup Environ Hyg 16(2):315318.
Oldershaw PJ [2002]. Control banding: an
overview. Presented at the First International Control Banding Workshop, London, England, 4 and 5 November.
Oldershaw PJ, Fairhurst S [2001]. Sharing toxicological information on industrial chemicals. Ann Occup Hyg 45(4):291294.
84
In 1998, the third largest manufacturing industry was chemical manufacturing, employing 1.7 million
people directly.
Several leading multinationals and
36,000 SMEs were involved.
Known adverse human health effects of many chemicals, and lack
of knowledge about the impacts of
many chemicals.
The number and volume of chemicals are
also driving chemical risk assessment in
the EU:
400 million tons of chemicals produced globally in 2001
100,000 substances registered in
the EU
10,000 chemicals marketed in volumes >10 tons and 20,000 marketed at 110 tons
The article describes the REACH system,
which is a regulatory system for chemical
control. The REACH system uses a tiered
approach to registration, triggered by production volumes. The proposed system
would result in critical information about
most chemicals being registered in a central database. Higher anticipated risks
would trigger higher levels of required information.
85
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
Measurement methods
profiles are the shortage of data, conflicting positions on data interpretation, poor
transfer of toxicological information, inefficiencies in the use of available resources, and inadequate understanding of the
science. Indications of progress include
increasing quantities of data (e.g., the
International Council of Chemical Associations commitment to baseline data on
the High Production Volume substances,
harmonizing positions on data interpretation, better transfer of toxicological data
to those exposed, more efficient use of
available resources, and improved understanding of the science). Oldershaw and
Fairhurst called for several elements to
improve data quality:
87
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
90
with nongenotoxic mechanisms and identifiable thresholds were allocated to Hazard Band D. Category 3 carcinogens with
genotoxic mechanisms were assigned to
Hazard Band E, as were Category 1 or 2
carcinogens, based on the EU Carcinogens
Directive. Substances with skin sensitizers and corrosive or severe irritant effects
were assigned to Hazard Band C based on
their identifiable threshold. Moderate eye
and skin irritants were assigned to Hazard
Band A.
Note: Only after a substances toxicological data are completely considered is it
assigned to a hazard band. A substance
should not be assigned to Hazard Band A
simply because of lacking data.
Stakeholders
Stakeholders include implementers (including employers), researchers and workers/users of chemicals. Bodies that may
be involved in the implementation of this
Strategy include: intergovernmental and
91
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
international non-governmental organizations (such as IOHA); government agencies; industry, including associations of
chemical producers and suppliers; employer and employee associations; industrial hygienists; labour unions; labour
inspectors; researchers; and training professionals.
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
International Technical
Group (ITG) Terms of
Reference and Membership
Terms of Reference
1. The functions of the ITG are:
Membership
The members of the ITG are experts from
the following organizations:
To provide guidance to the relevant lead body/bodies concerning the collection and dissemination of information on
activities.
International Research
Agenda
Qualitative Risk Characterization and Management of Occupational Hazards: Control Banding (CB)
element 7). Proposals that have come forward to date are listed below.
1. Chemical Toolkit Applications in
Developing Countries
Investigate applications within
large enterprises.
Develop tools for SMEs.
Effectiveness of predicting exposures.
Validation of controlling exposures.
Field test of current product.
Translation of concepts and
common phrases.
2. Other Applications in Developing
Countries
Focus on large scale industries, select appropriate industries and hazards.
Develop other toolkits for the
Occupational Risk Management
Toolbox.
Adapt existing approaches (e.g.,
WIND Program), build on successes.
Develop an ergonomics toolkit based on existing models.
3. Chemical Control Toolkit Applications in Developed Countries
96