Linda Schenk

Use of Uncertainty Factors by the SCOEL in their derivation of health-based Occupational Exposure Limits

The aim of this study was to investigate how the Scientific Committee on Occupational Exposure Limits (SCOEL) of the European Commission uses uncertainty factors when proposing health-based indicative occupational exposure limit values (IOELVs). In total, 75 IOELVs in 62 summary documents published from 1991 to 2003 were analyzed. For 31 of the IOELVs, no explicit uncertainty factor (EUF) was stated. For these, we calculated an implicit safety margin (ISM) as the ratio between the point of departure (POD, derived from the NOAEL or LOAEL of the critical effect) and the proposed IOELV. We further analysed whether date of recommendation, type of critical effect, nature of POD or amount of available data influenced the magnitude of the EUFs and ISMs. The ISMs varied little (range 1-5), while the EUFs showed more variability (range 1-50). The EUFs remained unaffected over time and the ISMs decreased slightly. Significant differences in the magnitude of the EUFs, but not ISMs, were found between critical effects, however, contrary to expected the average EUFs and ISMs for irritation were similar to those for more severe systemic effects. The nature of the POD affected the ISMs and EUFs only slightly and less than expected. Both EUFs and ISMs showed a weak but significant negative correlation with the amount of available toxicological data, measured as the number of relevant publications in PubMed, whereas SCOEL statements on data sufficiency had no influence. Overall, the most striking difference was that between EUFs and ISMs, the former being on average 2.1 times higher.

A quantitative comparison of the safety margins in the European indicative occupational exposure limits and the derived no-effect levels for workers under REACH

The new European Union (EU) REACH legislation requires derived no-effect levels (DNELs) to be calculated for substances produced in quantities above 10 tonnes/year. Meanwhile, the setting of occupational exposure limits (OELs) continues both at the member state and the EU levels. According to REACH, indicative OEL values (IOELVs) from the Commission may under some circumstances be used as worker-DNELs. On the other hand, worker-DNELs will be derived for several thousand substances, far more than the approximately 100 substances for which IOELVs have been established. Thus, the procedure to set health-based OELs may become influential on that of DNELs and vice versa. In this study, we compare the safety margins of 88 Scientific Committee on OELs (SCOEL) recommendations with those of the corresponding worker-DNELs, derived according to the default approach as described in the REACH guidance document. Overall, the REACH safety margins were approximately six times higher than those derived from the SCOEL documentation but varied widely with REACH/SCOEL safety margin ratios ranging by two orders of magnitude, from 0.3 to 58 (n = 88). The discrepancies may create confusion in terms of legal compliance, risk management, and risk communication. We also found that the REACH guidance document, although encompassing detailed advice on many issues, including default assessment factors for species and route extrapolation, gives little quantitative guidance on when and how to depart from defaults.

Are occupational exposure limits becoming more alike within the European Union

The occupational exposure limits (OELs) established by seven different national regulatory agencies of EU member states are compared with those of the European Commission (EC). The comparison concerned: (1) what chemicals have been selected, (2) the average level of exposure limits for all chemicals, and (3) the similarity between the OELs of different EU member states and the OELs recommended by the European Commission. The average level of the exposure limits has declined during the past 10 years in four of the five countries in our study for which historical data were available to us. Poland has not changed its level noticeably and Germany has increased it. Since the first list of indicative OELs was established by the EC, a few of the EU exposure limits have been lowered. The similarity index indicates that the exposure limits of EU member states are converging towards the European Commissions recommended OELs. Still, the average level of OELs differs between organizations – the Estonian OELs are on average 35% higher than the Polish OELs. Copyright

Occupational exposure limits in Europe and Asia – Continued divergence or global harmonization?

Occupational exposure limits (OELs) are used as a risk management tool aiming at protecting against negative health effects of occupational exposure to harmful substances. The systems of OEL development have not been standardized and divergent outcomes have been reported. However some harmonization processes have been initiated, primarily in Europe. This study investigates the state of harmonization in a global context. The OEL systems of eight Asian and seventeen European organizations are analyzed with respect to similarities and differences in: (1) the system for determining OELs, (2) the selection of substances, and (3) the levels of the OELs. The majority of the investigated organizations declare themselves to have been influenced by the American Conference of Governmental Industrial Hygienists (ACGIH), and in many cases this can be empirically confirmed. The EU harmonization process is reflected in trends towards convergence within the EU. However, comparisons of Asian and European organizations provide no obvious evidence that OELs are becoming globally harmonized.

Occupational diseases in the people's Republic of China between 2000 and 2010

BACKGROUND This study provides a description and analysis of the development of occupational diseases in China as recorded in the official statistics during the period 2000-2010, identifies major challenges, and explores possible solutions for prevention and control. METHODS In-depth textual analysis and data analysis of Chinas annual national reports of occupational diseases, as well as of corresponding policy and regulation documents. RESULTS The number of recorded cases of occupational diseases increased rapidly in China between 2000 and 2010. Pneumoconiosis was the most prevalent category of occupational diseases. Chemical poisonings accounted for 13% of the cases of occupational diseases. CONCLUSIONS Difficulties in diagnosis and inefficient surveillance are major impediments to the mitigation of occupational diseases. The new definition of occupational disease has provided an opportunity to enlarge the Catalogue of Occupational Diseases. Improved coordination of the different chemical regulations meant to protect human health may also facilitate the prevention of occupational disease.

Comparative analysis of toxicological evaluations for dermal exposure performed under two different EU regulatory frameworks

Dermal exposure to chemicals is highly relevant in relation to the use of cosmetic products, both in consumers and in individuals exposed occupationally. Regulatory frameworks exist within the EU to limit the dermal exposure of the general population and workers to chemicals in general, as well as to limit the use of certain substances in cosmetic products. The objective of the study was to investigate and compare toxicological evaluations of dermal exposure performed under current regulatory frameworks. The publicly disseminated hazard information under the respective regulatory frameworks was compiled and compared for the five substances resorcinol, p-phenylenediamine, p-aminophenol, N-phenyl-p-phenylenediamine, and diethylene glycol monoethyl ether. A low consistency between evaluations was observed in respect to data coverage and cited dose descriptors. No systematic differences over all five substances were identified from the viewpoint of dermal hazard assessment. The critical effect and corresponding systemic effect dose descriptor was identical for two substances, differed somewhat for two other (a factor of 2-2.5). For N-phenyl-p-phenylenediamine a critical effect was only identified under REACH.

Does industry take the susceptible subpopulation of asthmatic individuals into consideration when setting derived no-effect levels?

Asthma, a chronic respiratory disease, can be aggravated by exposure to certain chemical irritants. The objectives were first to investigate the extent to which experimental observations on asthmatic subjects are taken into consideration in connection with the registration process under the EU REACH regulation, and second, to determine whether asthmatics are provided adequate protection by the derived no‐effect levels (DNELs) for acute inhalation exposure. We identified substances for which experimental data on the pulmonary functions of asthmatics exposed to chemicals under controlled conditions are available. The effect concentrations were then compared with DNELs and other guideline and limit values. As of April 2015, only 2.6% of 269 classified irritants had available experimental data on asthmatics. Fourteen of the 22 identified substances with available data were fully registered under REACH and we retrieved 114 reliable studies related to these. Sixty‐three of these studies, involving nine of the 14 substances, were cited by the REACH registrants. However, only 17 of the 114 studies, involving four substances, were regarded as key studies. Furthermore, many of the DNELs for acute inhalation were higher than estimated effect levels for asthmatics, i.e., lowest observed adverse effect concentrations or no‐observed adverse effect concentrations, indicating low or no safety margin. We conclude that REACH registrants tend to disregard findings on asthmatics when deriving these DNELs. In addition, we found examples of DNELs, particularly among those derived for workers, which likely do not provide adequate protection for asthmatics. Copyright

Protection without Discrimination: Pregnancy and Occupational Health Regulations

Occupational exposures of pregnant workers can give rise to foetal damage. Two major types of strategies against detrimental effects on the foetus are described: differentiated protection that reduces only the exposure of pregnant workers (or only of female workers) and unified protection that reduces the exposure of all workers to a level that is sufficiently low to protect against detrimental effects on the foetus. The former strategy is shown to be inefficient, as it does not provide the desired protection. Protection only of pregnant workers is insufficient since protection is needed early in pregnancy when it is not known, and in the case of substances that are accumulated in the woman’s body even prior to conception. Protection of all women is also insufficient to protect the foetus since evidence indicates that preconception exposure of the father can also give rise to malformations. Furthermore, differentiated protection that requires more costly protective measures for women tends to aggravate the already prevalent discrimination of women on the labour market. It is therefore concluded that unified protection is the only efficient and non-discriminatory strategy against foetal damage.

Setting Risk-Based Occupational Exposure Limits for Non-Threshold Carcinogens

ABSTRACT Several regulators have recently issued so-called risk-based occupational exposure limits for carcinogenic substances, and also reported estimates of the risk of fatality that exposure to the limit value would give rise to. This practice provides an opportunity to study how differences in the exposure limits set by different regulators are influenced by differences in the scientific judgment (what is the risk at different levels?) and in the policy judgment (how should large risks be accepted?). Based on a broad search, a list was compiled of exposure limits for carcinogens that the respective regulator associates with a numerical risk estimate. For benzene, such data was available from six regulators. The differences in estimates of the risk/exposure relationship and in risk tolerance were about equal in size for benzene, while the range for acceptability was somewhat wider. A similar pattern was observed, although less clearly, for substances with data from only two or three regulators. It is concluded that the science factor and the policy factor both contribute to differences in exposure limits for carcinogens. It was not possible to judge which of these two factors has the larger influence.

Throwing the Baby Out with the Bath Water? Occupational Hygienists’ Views on the Revised Dutch System for Occupational Exposure Limits

In 2007, the Dutch Working Conditions Act was revised with the goal to decrease the regulatory burden, and to open up for company-specific solutions of establishing a safe and healthy work environment. One tool geared towards company-specific solutions is the compilation of the Arbocatalogs, which are company or sector-level collections of safe working methods and guidelines developed both by employers and employees. The revision also introduced a new occupational exposure limit (OEL) system in the Netherlands. This system encompasses two kinds of OELs: private and public. Private OELs are to be derived by the industry, while public OELs are issued by the Ministry of Social Affairs and Employment. With this change, the majority of the previously set Dutch OELs were removed, as the substances in question now are falling under the private realm. The motivations, expectations, and practical impacts of these revisions have been investigated through interviews with stakeholder organizations and a questionnaire study targeted at occupational hygienists. The questionnaire results show that although the Arbocatalogs seem to be relatively well received, a majority of the Dutch occupational hygienists are still relatively negative to the changes. There is a fear that private OELs will be less scientifically robust than public OELs and that the lack of robustness will have a negative impact on the field of occupational hygiene as a whole.