Letters to the Editor

Carpenter study misses ‘most salient’ point

As a safety practitioner in the state of Washington for 35 years, I read with interest an article in your recent publication titled, Study of carpenters finds lower rates of falls from height.

An apparent study by Duke University cites an 80 percent decrease in falls from height by union carpenters in my state from 1989 to 2008. The end of the article reads, “One reason for the decline may be state and federal fall protection standards… .” This article and study completely misses the most salient of points, known here as the Stute Decision (1990). This legal precedent placed the responsibility for workplace safety squarely on the shoulders of the general contractor, raising the stakes for enforcement of fall protection requirements on the job. Perhaps someone should let Duke University know what the primary reason for this decrease is, rather than speculating on what it may be.

Michael Garrison, ARM, ALCM, CSP
Seattle, WA

A sad display

The National Safety Council deserves great recognition for being at the forefront of the national epidemic of prescription drug abuse – specifically that of prescription painkillers. They’ve taken up the cause with research, information campaigns and instructional materials since deaths from overdose grabbed the lead from motor vehicle deaths in our country nearly 5 years ago. It should go without saying that these medications aren’t limited to their destruction within the walls of homes. Their use and effects obviously follow the abusers and misusers wherever they go, including the workplace. This is why safety professionals are in a unique position to do something about this epidemic. So why is our profession so silent?

The recent NSC Congress & Expo in Chicago included a newly featured Prescription Drug Keynote. This was a fitting offering for a large audience of safety professionals. With estimated attendance in excess of 12,000 people, one would expect this keynote to be a packed house. Instead, the turnout was about 80 concerned individuals. I’m not kidding. This equates to walking past a bleeding victim on the side of the road with disinterest. How can this happen? Why did so many fail to fill that auditorium? Certainly with the great number of people attending the conference, more than 80 have somehow experienced some form of pain or loss surrounding this issue.

There is much that we can do and much that the NSC can help us do. We can educate ourselves and educate our employees. Our employees can educate their families. We can learn about signs and symptoms of abuse. We can encourage employees to take charge of their situation following an injury and avoid prescriptions they have no intention of taking or limiting the amount prescribed. We can avoid sharing medications with others. We can properly dispose of medications. We can simply care enough to make this an epidemic of the past.

I hope that we continue to see these keynotes at future conferences. I further hope that safety professionals take a vested interest in a glaring problem and pack the house next time. If your life, your company or someone you know hasn’t been impacted by the avoidable tragedy of overdose, there is no sense in waiting until it happens. Because chances are disturbingly solid that it will.

Rex Butler, CSP, OHST
Manager, Environmental and Safety
Central Iowa Power Cooperative
Cedar Rapids, IA

Updated silica rule not ‘long overdue’

I read your article Long overdue in the October 2013 issue of Safety+Health and object to your conclusions.

Let’s start with the government’s own facts. Ten years ago the U.S. Centers for Disease Control and Prevention and the National Institute for Occupational Safety and Health (NIOSH) data showed that silica in 1968 was a contributing cause in just under 1,200 deaths in the U.S. By 1999, the number had dropped to less than 200. The most recent data from 2007 show that deaths from silica have now dropped to less than 100. Why does OSHA want to push for new exposure limits when the number of deaths attributable to silica has dropped dramatically and the industry has developed its own standards and regulations to protect construction workers?

Nearly 10 years ago OSHA was also proposing new regulations on respirable silica. The agency proposed a reduction of the permissible exposure limit (PEL) level from 1.0 to 0.25. The source for this proposal was based on OSHA’s experience in the manufacturing sector but showed its dismal lack of understanding of the construction industry, especially because it is almost impossible to measure at such levels in the field. The same is true for this new proposal.

The proposed standard then would have required construction companies to initiate many new procedures. An industrial hygienist would have been required to provide sampling services on each site. The contractor would also have to designate a “competent person” to identify and evaluate silica exposure hazards and establish a regulated workspace, perimeter and constant monitor the quality of the air. The contractor would have to make respirators and Tyvek clothing available to workers as well as anyone entering the jobsite – including trades working in adjacent areas. Medical screening and exam costs for employees would have skyrocketed.

Susan and the CSDA Safety Committee developed a simple chart that operators could use on the job to determine if respiratory protection was needed and, if so, what type of protection was recommended. This chart was based on an extremely thorough data collection of cutting job sites from members and NIOSH. CSDA even invited NIOSH to attend CSDA training classes at St. Petersburg College to observe and advise CSDA. Because of the use of water in the cutting operation, NIOSH recognized that there were very few silica exposure problems for cutting contractors. This chart that was developed has been used by members over the past decade and has simplified procedures and protected workers at the same time. CSDA makes this chart available to anyone in the industry.

I know that the OSHA folks who issued this new proposed rule not only do not talk to the construction industry, they do not even talk to their own construction folds within OSHA. So I disagree with the title of your article. The industry has done much to protect workers and the data show that to be the case. So a new ruling is not overdue in my understanding.

Pat O’Brien
Executive Director
Concrete Sawing and Drilling Association
St. Petersburg, FL