Wednesday, January 21, 2009

IH Inspections

The OSHA Underground blog had another interesting post today, in part by "CSHO Annie," who did an evaluation of IH inspections by IHs within the agency. The evaluation certainly wouldn't meet the rigors of a scientific study considering the factual errors, like the implication that there are 8 IHs in the Boise Area office (there are, I think, 3, the whole office only has 10 compliance officers) or Region 3's hiring of two ADs from southern regions (the AD in Charleston spent a short time in Mobile, before that he was in Boise, and the AD in Baltimore/Washington was previously in Wilkes Barre and before that in, *gasp* the National Office), or the implication that the NO didn't know about the decline (Rich Fairfax, the head of the Directorate of Enforcement Programs, has been pointing this out for several years now).

On the surface, Annie's analysis is condemning, however, it's also very incomplete. What she never takes into account is the fact that over half of our inspections are based on complaints or referrals. Experience suggests that few complaints/referrals are health related, they are mostly safety complaints. If she were to run the numbers based strictly on programmed inspections, I think it would show a significantly different story.

The other thing she never considers is that maybe, just maybe, after all of this time we are beginning to have a positive impact on health related issues in the workplace in this country. Maybe.

My frustration is, again, where and how THEY try to place the blame. I'm not going to defend the Bush version of OSHA, nor am I going to say that reinvention was the greatest thing since sliced bread, however, this trend began to show up before the Bush administration and before reinvention.

What I do read into her story, however, is that she is an old school IH who isn't comfortable doing safety inspections and wants to go back to the days when IHs did only IH inspections and safeties did only safety inspections. As an IH, I hate the old school ways (even though I'm old and lived through them). Give me some variety, give me some job enrichment, I want to do some safety inspections damnit!

[It's also kind of interesting to note that the OSHA Underground keeps harping on the agency for not doing enough crane or dust inspections (both safety inspections) and then they publish a post that says IH's are doing too many? Hmmm, hypocrisy is a wonderful thing isn't it?]

Then, of course Kane had to add is two warped-sense (that wasn't a misspelling, it was a play on words, think about it).

When IH's are averaging over 50 inspections, WE know the numbers are more important.” Really? “WE are hardly doing full shift sampling anymore.”

It's time for me to hazard a guess that Kane isn't an IH and has never conducted an IH inspection. If he was and IH/CSHO he would know that less than 10% of all of the samples we take show an overexposure (and probably less than 5% of the sites where we sample have overexposures). This number has fluctuated slightly over the last 35+ years, but only slightly. As an IH who has conducted IH inspections and has sampled, I can tell you it would be a tremendous waste of time to do full shift sampling on at least 80% of the sites we do sample. Why? Because most of the IH inspections we do aren't about showing overexposures, they are about just the opposite, showing there aren't airborne levels high enough to cite or cause health effect.

I remember a referral I did at a video rental store. A physician had a patient who showed signs of overexposures to carbon monoxide so he contacted us. Lucky me, I go to spend the afternoon (actually it turned out to be less than 2 hours) in a video store conducting interviews and taking measurements, all the while the real cause of the employees exposure went unchecked (as most people out there who know anything about CO might have guessed, it was a problem with the employees furnace). Should I have done the opening conference in the afternoon, then contacted the lab to send me the gas sampling bags so I could do full shift sampling two days later? I hope you said NO! Full shift sampling should be the exception, not the norm.

It has become very rare for us to have a good, old fashioned IH mystery any more. Why? Because most industries and processes have been pretty well profiled by now. That doesn't mean something like food flavoring won't show up now and then, but it does mean that any IH who has been around more that 5 years already knows what to look for, and the good ones will know almost every time whether or not there is an overexposure before the results are even back. In other words, experience counts.

WE want a return to a safety and an IH module in each office.” God save us from this. Most, but not all, of the IH CSHOs I know (and I know a lot) hate this idea, even the old timers.

OSHA purposely hides it health sampling results so that it is not accessible to the public or its staff. Are workers exposed to diacetyl more than 3 years ago? They can't tell.” Really? I'm on the staff and I know where to get these numbers. Certainly the stats aren't right at everyones finger tips, but that has more to do with that antique we call the Integrated Management Information System (IMIS) than any attempt to hide the information. I've worked on the IMIS redesign, once the new system is up and gets integrated into the lab's system, that information should be easily available to anyone. Until then, I know where to look, it's just too bad Kane hasn't bothered to ask.

(note: this entry was edited on 3/6/09, the quotes from Kane were bolded, no other changes were made)

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