HAZARD AND RISK ASSESSMENT, ETHICS IN INDUSTRIAL HYGIENE PRESENTATION BY MAHARSHI MEHTA AT NIHC

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Hazard and Risk Assessment

• Ethics in Industrial Hygiene
• National Conference in Industrial Hygiene
• February 14, 2014

• Maharshi Mehta, CSP, CIH
• International Safety Systems, Inc.,
  Washingtonville New York, USA
• www.issehs.com

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Agenda

• Introduction to Ethics in Industrial Hygiene
• Current Situation
• Elements
• The need
• Professional
• Personal
• Religion and ethics
• Place of worship (temple, synagogue, mosques VS
  Workplace)
• Gods Vs Stakeholders
• Benefits - Case Studies
• Conclusions

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Current situation

• Exposure control decisions seem to be made based
  on erroneous data at 50 workplaces
• One or more of reproducible, representative and
  reliable data missing
• Issues with sampling and analytical methods
• Greed has no lid
• Knowingly results are delivered what company or
  client is looking at some of the workplaces
• Financial gains at the cost of integrity

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Issues with sampling and analytical methods

• Collect more samples in limited time
• Exposure numbers, no indicating on what is
  contributing to exposure
• Reproducibility
• 1 sample
• Reliability
• Calibration
• Laboratories analyzing samples
• Representativeness
• Sampling durations
• Focus on monitoring and not on exposure controls

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The Need-Professional

• Impact on Stakeholders
• Employee
• Reputation
• ABC Environmental company in China
• Trust
• Financial and standard of living
• Business Growth word of mouth

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The Need-Other

• Impact on Family, Society and Nation
• Family
• Values in children and other family members
• Bonding and benefits of bonding
• Friends
• Ever widening virtuous circle
• Nation
• Erosion of values
• Economical impact
• Impact on individual
• Effective utilization of latent ability
• Peace of mind
• Growth

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Gods VS Workers and Family
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Temples Vs. Workplaces and Homes-True Haven
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Examples All Around Us- Cost to Shareholders

• Enron collapsed in 2001 costing shareholders
  74B and prompting Sarbane-Oxley Accounting
  Regulation.

• WorldCom-11B.

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How Do Professionals Use a Code?

• As The Law?
• -- (Enforceable v. not enforceable?)
• As a set of guidelines?
• As a means to set a baseline standard of
  practice?
• As a way to raise the level of practice?

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Code History

• Originally Adopted Early 80s
• Revised Mid 90s
• Cannons with Interpretive Guidelines
• Joint IH Ethics Education Committee (JIHEEC)
• March 2006 Meeting
• ABIH, ACGIH, AIH, AIHA JIHEEC
• ABIH Legally Enforceable Code of Ethics May
  2007
• Diplomates, Applicants Examinees

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What the Code Is and Is Not

• A guideline for professional ethical decisions
• Not a black and white set of rules
• Not a replacement for good judgment
• http//www.abih.org/downloads/ABIHCodeofEthics.pdf
  

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IH Ethical Misconduct Examples

• Borrowing from anothers proposal
• Deliberate failure to control data quality
• Failure to protect confidential data
• Release of results of study before peer review
• Avoiding competition by refusing to share data
• Research designed to favor a specific result
• Fabrication of data
• Deliberate failure to disclose sources of support

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Ethical DilemmaExposure assessment for
formaldehyde in manufactured housing is
contracted and scheduled for a specific week with
an industrial hygiene consultant. The contract
is for the collection of the data only. The
hygienist will not have access to the analytical
results or be involved in writing the report.
The client changes the date twice for reasons not
explained. The industrial hygienist arrives on
site ready to conduct the study, but it begins to
rain. Rain is projected for the entire week of
the study and the relative humidity is projected
to be between 85-95.
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A call to the laboratory and the sorbent tube
media manufacturer confirms that the high
humidity environment will skew the results low if
the data is used. Upon informing the client of
the current circumstances for performing the
exposure assessment, the client complains that
the hygienist is being too cautious and should
collect the data anyways.
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What are Potential Responses?

• Refuse to collect any further samples
• Collect and submit the samples and contact the
  laboratory to report field conditions
• Collect the samples and report nothing
• Collect the samples and require that the client
  submit them to the laboratory

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What are the Likely Outcomes of the Responses?

• Integrity of the Samples
• Integrity of the Client
• Role of the Laboratory and Media Manufacturer
• Long-term Responsibility Social Justice Issues

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Ethical Dilemma

• You are bound by a contract to protect the
  confidentiality of the project for which you are
  hired. Because of the complexity of the IH
  issues, you wish to obtain input from a
  professional peer regarding the technical aspects
  of the project.

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What are Potential Responses?

• Ignore your desire to obtain input from a
  professional peer because it could be considered
  an ethical breach of your clients
  confidentiality.
• Discuss the project without disclosing
  confidential details such as the name of the
  company, individual names, proprietary or other.
• Discuss in full disclosure with a professional
  peer who is unrelated to the project and lives
  thousands of miles away.
• Consider publishing your quandaries in the next
  edition of the Synergist.

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What are the Likely Outcomes of the Responses?
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Ethical Dilemma

• You witness what you feel is a violation of the
  code by one of your professional peers who is a
  CIH. She agrees with her boss to date a safety
  review earlier than it was conducted, so it lines
  up closer to when the issue was identified.

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What are Potential Responses

• Contact anyone you can think of along with ABIH,
  and/or AIHA and report the incident.
• Submit a written allegation of a breach of
  ethical duty or professional responsibility to
  the chair of the JIHEEC.
• Call the AIHA President to personally complain.
• Explain to the peer that you feel they are acting
  unethically and give them an opportunity to
  correct the situation before taking further
  action. If it remains unresolved then you could
  submit a written allegation of a breach of
  ethical duty or professional responsibility to
  ABIH.

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Ethical Dilemma

• You are invited by a vendor who provides a
  majority of your industrial hygiene laboratory
  services to play golf and have dinner at an
  exclusive country club.

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What are Potential Responses?

• Accept the offer and ask if he wouldnt mind
  throwing in a sleeve of balls and a hat.
• Investigate your companys policy on accepting
  vendor gifts and determine the best course of
  action with your supervisor.
• Decide to accept the offer, but only if you can
  pay for your own green fees and dinner.
• Accept the invitation but insist that the bill be
  paid in cash instead of a credit card to avoid
  leaving a paper trail.

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Ethical Dilemma

• As an IH consultant you are asked by a major
  insurance carrier to sample for mold in a
  residential setting. One of the homes occupants
  is recovering from cancer and recently had a bone
  marrow transplant. Moderate to extensive visible
  mold is present throughout the home and you
  recommend relocating the family. The insurance
  carrier disagrees and asks you to keep your
  mouth shut or they will take legal action.

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What are Potential Responses?

• Wonder why you chose to be a consultant and run
  out of the building screaming.
• Keep your mouth shut and pretend it never
  happened.
• Ignore the insurance carriers threats and
  immediately notify the occupants to vacate the
  premises.
• Contact a close friend, attorney and/or mentor
  and ask for additional advice and direction.

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Challenges encountered-Ethical Approaches adopted

• Filter fell off during sampling operator
  connected upside down
• Calibrator did not function only 3 days in
  Australia
• Middle man ask for of the total project cost
• After leaving company, professionals learns about
  environmental violations
• Collect 10 samples/day by calling operators in
  lunch room and remove samples at the end of day
• Spray welding exposure below limit-of Cr3 and Ni
  elemental potential for hexchrome insoluble Ni
  exposure to exceed OEL exits, recommend RPE,
• Toluene exposure likely to exceed somewhere in
  Europe
• Pharma clients ask not to mention exposure is
  above OEL in report
• Friend for 20 years ask not to write about
  system not working just list exposure above limit
  for new operation

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Case Study Construction Safety

• EHS professional in financial crisis finally gets
  job in middle east
• Manager sends letter to all EHS managers has full
  authority to even close the work for safety
  violations and calls EHS professionals in office
  and conveys sit in the office dont go out we
  will give you salary-relax and enjoy
• What would you do?
• Mobile Crane is to be used at site without
  testing Managers threatens EHS person you will
  loose job if you insist on testing, what would
  you do?

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Sources and Further Reading

• How Good People Make Tough Choices, Rushworth M.
  Kidder,1995
• Business Ethics, Richard De George
• Ethical Issues for Industrial Hygienists
  Survey Results and Suggestions, Laura A.
  Goldberg Michael R. Greenberg, March 1993 AIHA
  Journal
• Observations of Ethical Misconduct Among
  Industrial Hygienists in England, Burgess G. L.,
  Mullen, D., AIHA Journal (63) March/April 2002
• ABIH Executive Director, Lynn ODonnell, 2011
  Data
• http//www.abih.org/downloads/ABIHCodeofEthics.pdf
  
• Lectures shared by Jeff Throckmorton, David
  Roskelley, Barbara Weeks, Pam Greenley, Steve
  Rucker

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Beyond Reading - Action

• JIHEEC Mission
• Promote an awareness and understanding of the
  enforceable code of ethics published by the ABIH
• Not an enforcement group or resolution board
• Publishes case studies of ethical dilemmas in the
  Synergist

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Business Ethics Codes

• Premise
• Business integrity earns respect and brings peace
  in our lives
• Transparency and ethics have positive impact on
  generations to come
• Codes
• Do not give, receive bribe in any form cash,
  favor, kind, gift, commission
• Do not compromise on identified risk in
  reporting, among other things
• Ensure sound basis
• Offer to take client out for lunch/dinner once,
  do not push. Offer to pay for lunch/dinner, do
  not push, go Dutch

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Confidentiality Codes

• Significance
• Most Sensitive information
• Clients trust on us
• Do not communicate verbally or in writing what
  you saw at site especially process details and
  findings with any one out side ISS and in ISS
  with affected persons only
• Data protection Password when you are not around
  in your laptop, no one should have access to your
  hard disk, place relevant information in
  centralized storage and delete from file
• Digital images
• Obtain permission
• Do not take if it does not serve purpose
• Avoid taking entire process large area, take what
  you want
• Do not show images to ANYONE. Delete them once
  purpose is served
• Keep only good images and provide to Chirantan or
  centralised storage and then delete all images

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One can make decent leaving even by following
business ethics-Then
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Now
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Conclusion

• Listen to inner voice and implement