The future of work and its impact on OHS pros

Separating the H&S
    In consideration of the future of OHS work, I separated health from safety. For various reasons I believe that there will likely be greater risk for “safety” job loss when AI and its technology partners get on a full roll. AI, however, is likely to enhance health i.e. industrial hygiene responsibilities. The following are a few reasons for this belief.

IH codified into laws
    The “industrial hygienist” title rather than a safety or similar title continues to have important responsibilities reaffirmed or woven into OSHA laws. The May 22, 2024, Federal Register (89:45026-45028), for example, contains a request from the DOL to the OMB to continue information collection at 29 CFR 1915.7(d) by “competent persons, marine chemists, and certified industrial hygienists (CIHs) (bold my emphasis). OSHA 1915.7(c)(6) requires a CIH® within the shipyard industry when dangerous atmospheres cannot be adequately assessed by lesser qualified people. Except for OSHA 1915.7(c)(6) and the mention of CIH® no other OSHA regulation has an OHS certification codified into law. However, the intent to elevate the industrial hygienist qualifications exists in other OSHA regs.

OSHA air contaminants standard
    For example, OSHA’s air contaminant standard at 1910.1000(e) includes, in part, that “Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist (my emphasis) or other technically qualified person. As above in 1915.7(d) a “competent person” is determined by the employer. An employer is also responsible to determine who qualifies as an “other technically qualified person.” There is no question that a CIH® is a competent industrial hygienist and a technically qualified person.

OSHA HazCom standard
    OSHA’s final rule to update its Hazard Communication standard, effective July 19, 2024 (see FR Vol. 89, May 20, 2024), reaffirms at 1910.1200(i)(3) that an industrial hygienist (my emphasis) is a “health professional” along with newly revised “PLHCP” (physician or other licensed health care professional) and toxicologist, or epidemiologist. These select job titles alone are authorized by OSHA to receive from chemical manufacturers, importers, or employers “withheld chemical identity or exact concentration range” of SDS chemicals during non-emergency situations. Occupational safety and environmental professionals with various titles or credentials e.g. Certified Safety Professional CSP® are not granted these responsibilities by OSHA.

OSHA medical and exposure records standard
    OSHA standard on employee access to medical and exposure records at 1910.1020(c)(9) states that “Health Professional means a physician, occupational health nurse, industrial hygienist (bold my emphasis), toxicologist, or epidemiologist, providing medical or other occupational health services to exposed employees.” Look for OSHA to revise the 1910.1020 standard in the future to replace “physician and occupational health nurse” with “PLHCP” to align with the newly revised HazCom standard. Again, OSHA authorizes the industrial hygienist to do things that occupational safety and environmental titles are not permitted to do.

EEOC PWFA
    The industrial hygienist title has also found its way into the EEOC’s Pregnant Workers Fairness Act final rule, effective June 18, 2024 (see FR Vol. 89, No. 77, April 19, 2024). The PWFA is now being recognized as a new occupational health law. Section 29 CFR 1636.3(l)(i)(B)(3) of the PWFA defines a “health care provider” to include, but is not limited to: “doctors, midwives, nurses, nurse practitioners, physical therapists, lactation consultants, doulas, occupational therapists, vocational rehabilitation specialists, therapists, industrial hygienists (my emphasis), licensed mental health professionals, psychologists, or psychiatrists. The PWFA authorizes the industrial hygienist to do things that occupational safety and environmental titles are generally not allowed to do.

State title protection laws
    Many OHS pros are not aware that their state may have laws and administrative rules on occupational title protection. For example, Ohio Administrative Code, Title 47, Chapter 4777.01 (June 30, 2006, version), states "The practice of industrial hygiene means the anticipation, prevention, recognition, evaluation, elimination, and control of environmental, biological, chemical, physical, and ergonomic factors and stresses arising in or from the workplace that may cause sickness, impaired health and well-being, or significant discomfort among workers or the general public.”Chapter 4777.04 states in part that, “The following persons are not prohibited from engaging in the practice of industrial hygiene” a person working as an apprentice under the supervision of a CIH® or a person engaging in the supervised practice of industrial hygiene or through a course of study in that practice. Additional legalese can be found in Chapter 4777.01-4777.04 of the Revised Code.
    I am not an attorney so take the following comments as non-legal advice: I interpret the full language of Ohio Administrative Code, Title 47, Chapter 4777.01-4777.04 to mean: Anyone may call themselves an industrial hygienist and practice industrial hygiene so long as they do not represent themselves as a Certified Industrial Hygienist CIH®. For clarification, confirm my belief with an attorney familiar with your state laws and administrative rules.

Prepare for the future
    It’s expected that every OHS job has a list of tasks or responsibilities prepared by Human Resources. I believe that every OHS job with a safety title also performs many industrial hygiene tasks. This belief is because the difference between an injury (safety) and illness (health) causation from a workplace hazard is time. An injury occurs immediately. An illness develops sometime after immediately.
    As strategy for the future, request your HR representatives to include industrial hygiene as one of your responsibilities. If your sub-title includes “industrial hygienist” it is all the better. Be aware, you do not have to belong to an organization such as AIHA or ACGIH to be a recognized industrial hygienist, although membership in these types of organizations will be helpful.