Background
EPA announced the Chemical Right‐to‐Know Initiative on Earth Day 1998. One of its goals was to ensure that adequate data be made publicly available to assess the special impact that industrial chemicals may have on children. Toward meeting this goal, EPA identified industrial/commercial chemicals to which children have a high likelihood of exposure and the information needed to assess the risks to children from these chemicals. EPA pursued the collection, development, and public dissemination of this information through the VCCEP.
In August 1999, EPA announced the initiation of a stakeholder involvement process to get input on all aspects of VCCEP. EPA held three public stakeholder meetings and took comments on possible designs for a voluntary program. EPA also took steps to consider animal welfare and to reduce, or in some cases eliminate, animal testing, while at the same time ensuring that public health is protected. After considering all the comments of interested stakeholders, the Agency developed the VCCEP Pilot.
3.13.2 Voluntary Children's Chemical Evaluation Program (VCCEP)
On 26 December 2000, EPA launched the Voluntary Children's Chemical Evaluation Program (VCCEP) Pilot by asking companies that manufactured or imported one or more of the 23 chemicals selected for the program to volunteer to sponsor their chemicals and provide information on health effects, exposure, risk, and data needs. Thirty‐five companies and 10 consortia responded, volunteering to sponsor 20 chemicals.
Under the VCCEP Pilot, EPA collects three tiers of increasingly detailed information on a chemical from its sponsor. EPA asked companies to volunteer to sponsor their chemical(s) for Tier 1. After completing the evaluation of some Tier 1 chemical assessments, EPA determines if additional data is needed. EPA gives sponsors the opportunity to commit to one tier at a time. Companies are only asked to sponsor particular tiers when EPA believes the data to be provided are necessary to understand the chemical's potential impact on children. During their sponsorship, companies collect and/or develop health effects and exposure information on their chemical(s) and integrate that information in a risk assessment. A “data needs assessment,” also developed by the sponsor, discusses the need for additional data, which can be provided as part of the next tier of information to fully characterize the risks the chemical may pose to children.
3.13.2.1 Alkane Example
Three of the chemicals chosen for the pilot were n‐decane, undecane, and dodecane. These chemicals were sponsored in the pilot by a consortia organized by the ACC. The ACC n‐alkanes VCCEP Consortium Tier 1 submission was reviewed by an independent peer consultation panel in September 2004. That review and EPA's analysis resulted in a short list of additional data/analysis. One item was occupational exposure monitoring data at n‐alkane production facilities. Consortia members had previously checked for this type of data and found that none existed. Traditional IH assessment strategies would not necessarily have developed quantitative data for these alkanes since none of these chemicals have established occupational exposure limits, they exhibit low inherent hazard and none have been identified as causing unique workplace exposure concerns.
EPA's stated reasons for wanting the exposure data was to ensure they could adequately address risks to prospective parents. The data would demonstrate to EPA that the exposures (and corresponding risks) are low, thereby eliminating the need to consider the need for a two generation reproductive study. These studies are costly (frequently $1 million or more) and raise animal welfare issues. There is no guarantee that if these data are collected, EPA will not require such a study, but all the options would be reviewed more rationally.
3.13.2.2 The Solution
In response to EPA concerns regarding workplace exposures, the sponsoring companies gathered IH to develop a sampling and analytical strategy for these alkanes. Working with a certified Industrial Hygiene Laboratory the analytical method and sampling strategy was agreed to. The companies did workplace exposure monitoring and collected the data for a joint submittal to EPA. Monitoring results showed exposures to be below 0.2 ppm.
After reviewing the data EPA was satisfied that there was no additional information needed to demonstrate low exposure potential and no additional toxicity testing was requested.
This result demonstrates the value of exposure assessment and IH involvement in “voluntary” agency‐sponsored PS initiatives. Information on VCCEP and this example can be found on the USEPA website at https://chemview.epa.gov/chemview.
3.14 History of Product Stewardship
It is difficult to find the source or the time for the origin of the modern PS concept. While the first public concerns about the chemicals began to be known in the early 1960s the concerns generally revolved around their environmental impact. However, the focus on products from cradle to grave evolved over time as a key element in industry activities and programs. This approach was accelerated by notable catastrophic events and began to take a more organized or program‐oriented shape in the mid to late 1980s. Industry leaders quickly recognized that the management of chemical products and their potential impact on people and the environment was a continuum; it could not stop at the plant gate. Although customers and other product handlers had to take on their own responsibilities in use and disposal, chemical companies had growing motivation that drove them to advise and assist those customers with proper handling. In fact, companies might even withhold products from customers who failed to handle them appropriately, thus practicing true PS. Industry leaders also realized that the public would not understand differentiations about who had control of a product at any one time nor would the media encourage that understanding to take place.
4 A DISCUSSION OF COMPETENCIES COMMONLY EXHIBITED IN INDUSTRIAL HYGIENISTS
To understand what an IH is one can start by reviewing some accepted definitions of the IH profession. The following definitions/descriptions of Industrial Hygiene are offered merely as examples of the many that can be found. Each can add a little insight into the knowledge, motivations, duties, and competencies shared by those who practice IH.
Probably the single most quoted (or paraphrased) definition of IH is
The Anticipation, Recognition, Evaluation, and Control of Workplace Health Hazards.
This short description not only implies the overarching mission of IH but also outlines what could be considered as the four distinct stages of comprehensive IH practice.
The American Industrial Hygiene Association (AIHA), the largest global membership organization for IHs, defines Industrial Hygiene as the
Science and art devoted to the anticipation, recognition, evaluation, prevention, and control of those environmental factors or stresses arising in or from the workplace which may cause sickness, impaired health and well‐being, or significant discomfort among workers or among citizens of the community.
Correspondingly, the AIHA defines IHs as
Scientists and engineers committed to protecting the health and safety of people in the workplace and the community.
The American Board of Industrial Hygiene (ABIH), the largest global IH Certification Organization, describes the scope of technical knowledge assessed in their certification process as follows:
Basic Sciences Occupational disease, illness, injury, and surveillance
