A proposed update to the NIOSH policy for identifying occupational carcinogens and recommending exposure limits will extend the use of outdated hazard assessment practices. As ACMA will argue in its comments on the proposed policy, the eventual assessment of styrene and other substances under NIOSH’s new approach will further confuse workers regarding their risk of cancer, and place additional burdens on manufacturers and other employers.
The National Institute of Occupational Safety and Health, part of the Department of Health and Human Services’ Centers for Disease Control and Prevention, bills itself as “the primary federal agency charged with conducting research and making recommendations for preventing occupational injuries, illnesses, and death”, and adds that it “has unique expertise in assessing occupational risks”. NIOSH recommendations are intended to be an informative resource for employees, employers, and occupational health and safety regulatory agencies. Unlike OSHA, NIOSH has no duty to consider technical or economic feasibility when making recommendations.
Under its current policy, NIOSH designates a chemical as a potential occupational carcinogen if it determines through its own review of scientific data that exposure to the substance causes an increased incidence of tumors in humans. NIOSH recommends that workplace exposures to carcinogens be limited to “the lowest feasible concentration”.
Yet another scheme for classifying workplace carcinogens
Under its Nov. 5 proposed approach, the first step in NIOSH’s evaluation of substances known to have potential workplace exposures will be to refer to cancer classifications by EPA, the National Toxicology Program, and the International Agency for Research on Cancer. For substances listed as carcinogens under one or more of these programs, NIOSH will evaluate the relevance of the listings and associated narratives (such as the Report on Carcinogens monograph accompanying NTP’s “reasonably anticipated carcinogen” listing for styrene) to assess the relevance of this information to workplace exposures.