Open science

It’s a necessity for OHS best practices

OSHA’s epidemiology standard
    Many OHS pros participate in scientific research without their realization. Epidemiology is one example. Epidemiology is the study of the distribution and determinants of health-related states or events in specified populations and the application of this study to the control of health problems. Among other things, OSHA 1910.1020 Employee access to exposure and medical records is designed for epidemiological purposes.
    Most OHS pros and many employees should be aware of 1910.1020. The standard requires, for example, that upon an employee’s first entering into employment, an at least annually thereafter, each employer shall inform current employees covered by this section of the following: one the existence location and availability of any records covered by this section; two, the person responsible for maintaining and providing access to these records; and three, the employee’s rights of access to these records
    OSHA 1910.1020 applies to each general industry, maritime, and construction employer who makes, maintains, contracts for, or has access to employee exposure or medical records, or analysis thereof, pertaining to employees exposed to toxic substances or harmful physical agents. Toxic substances or harmful physical agent means any chemical substance, biological agent (bacteria, virus, fungus, etc.), or physical stress (noise, heat, cold, vibration, repetitive motion, ionizing and non-ionizing radiation, hypo- or hyperbaric pressure, etc.). Exposure record includes environmental (workplace) monitoring or measuring of a toxic substance or harmful physical agent, including personal, area, grab, wipe, or other form of sampling, as well as related collection and analytical methodologies, calculations, and other background data relevant to the interpretation of the results obtained.
    OSHA 1910.1020 requires that each employee exposure record, that includes SDSs and chemical inventories, shall be preserved and maintained for at least thirty (30) years. The length of time is the major clue that the standard is designed for epidemiology purposes.
    Individually or collectively 1910.1020 data is there to be researched by the employer or others. A careful review of the standard, especially a clear understanding of the definition of employee, that includes a deceased employee, and how access to records is granted is very important. Undoubtedly, 1910.1020 is science – but when may or should the data become open science?
    Most of new science knowledge is created by the business sector and withheld from public scrutiny, per the ISC. Trade secrets, confidential business practices, patents, and such, are fair and proper for competitive business. OSHA 1910.1020, however, is one example where employer generated science may be difficult to shield from scrutiny by those with a keen understanding of how this information may accessed. EPA Form R and other employer chemical use reporting requirements available to the public may be combined with 1910.1020 data and used in various ways.

Reports
     Over the past 30+ years I have created hundreds of reports subject to 1910.1020 requirements. Each of these reports adheres to basic scientific method outline that begins with a Title Page followed by summarized sections that include Introduction; Conclusions; Recommendations; Monitoring Strategy (includes sample and analytical methods, equipment calibration data, etc.); Results (generally presented in tables with PEL and TLV comparisons); and Discussion (generally includes observation on hierarchy of controls e.g., exhaust ventilation and PPE). Over the past few years, I have included more “professional judgement” comments within the report’s Discussion section. Reports rarely include photos. Reports rarely exceed ten pages, including attachments e.g., copy of lab report. Reports are written with the expectation that sometime, maybe even decades into the future, they may be used by other people for epidemiology or other purposes. Other purpose examples include that on occasion, some reports are identified as “confidential and privileged” information prepared under attorney direction in anticipation of litigation.

Historical – open science
     Lately, I have been reading open science articles in “The Journal of Industrial Hygiene.” Interestingly, this particular journal was published from 1919-1935. See reference 2 for more information. For perspective, ACGIH and AIHA were founded, respectively, in 1938 and 1939. The forerunner of JOEH was not published until 1940. The articles in the historical journal were made available by new technologies where pages are scanned and “Digitized by Google” and made freely available online, even without copyright protections, to the public. Initial observation: we can apply open science from the past to improve the OHS future.