Application of Toxics Use Reduction to OSHA Policy and Programs.
Source: The Toxics Use Reduction Institute, University of Massachusetts Lowell,Lowell, MA. Methods and Policy Report No. 12. Application of Toxics Use Reduction to OSHA Policy and Programs. Abstract Until recently, environmental and occupational health concerns about toxic substances were neatly demarcated at the roof, walls or property line of the industrial plant. Inside was the territory of occupational safety and health representatives, professionals and regulators. Outside was the purview of environmental advocates. When environmentalists realized that "end-of-pipe" solutions to toxic wastes were not working, and turned their attention to the source of environmental toxics in production processes where chemicals were used and produced, this clear line began to disintegrate. It has not, however, disappeared. Although the locus of attention for environmental solutions has shifted to the inside of the plant and to the workplace sources of toxic contaminants, the concern of environmental regulators and advocates about impacts continues to be focused primarily ourside the plant. Relatively little attention is paid to worker health and safety when it comes to targeting priority substances for use reduction or choosing alternative processes to current toxic ones. For its part, the occupational health field has not yet embraced the primary prevention perspective of toxics use reduction. It remains fixed on an engineering control framework, with local ventilation the solution of choice. And yet, it is common sense that worker protection from exposure to toxic substances is most effective when they are eliminated from the workplace or drastically reduced. This report surveys the options which can be used to reduce the use of toxics in the workplace, and the suggests differences in the ways in which occupational health representatives and professionals might look at toxics use reduction for occupational health purposes. It also examines OSHA's current regulations, policies and programs with respect to toxic substances, and suggests ways in which these can provide opportunities or obstacles to promoting toxics use reduction for occupational health. The report suggests that a shift in mindset in the occupational health community is necessary for OSHA to embrace toxics use reduction as a primary means of protecting the health of workers. It recommends ways in which the Work Environment Program and the Toxics Use Reduction Institute at the University of Massachusetts Lowell can take further leadership to make this shift happen. And finally, the report suggests a number of initiatives which OSHA could undertake or investigate and promote the practical application of toxics use reduction initiatives in occupational health. Authors: Jennifer Penney and Rafael Moure-Eraso. 1995.
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