Have an Opinion about Control Banding? Tell NIOSH by July 11

NIOSH recently released a draft document about control banding and would like to hear your thoughts on it. The document, Qualitative Risk Characterization and Management of Occupational Hazards (Control Banding [CB]): A Literature Review and Critical Analysis, describes the evolution and concepts of control banding, a qualitative approach for assessing and managing hazards associated primarily with chemical exposures in the workplace. It is posted at www.cdc.gov/niosh/review/public/138/.

As background to the topic of control-focused chemical hazard strategies, NIOSH says it recognized that the number of chemicals in commerce is far greater than the number of occupational exposure limits (OELs, roughly 1,000). Setting additional OELs for new and existing chemicals, and monitoring to ensure exposures are maintained below the OELs, are important but resource-intensive activities, the agency notes. In addition, if the majority of chemical substances in commerce have no established OELS, employers and workers often lack the necessary guidance on the extent to which occupational exposures should be controlled.

To fill this gap, control banding evolved as an approach to address these challenges, drawing upon mature knowledge and practices in occupational hygiene practice regarding exposure assessment, chemical hazard assessment, and control technology options. The conceptual basis for control banding is a framework for the grouping of chemical exposures according to similar physical and chemical characteristics, intended processes/handling, and anticipated exposure scenarios (amount of chemical used and how workers would be exposed). NIOSH says the promise of such a qualitative risk assessment and management approach is further increased given appropriate consideration for evolving developments in international chemical commerce, including the globally harmonized system of classification and labeling of chemicals (GHS), the OSHA proposed-rulemaking for the Hazard Communication standard, and European Union regulations (i.e., Registration, Evaluation, Authorisation and Restriction of Chemical substances, or REACH). These and other factors are discussed in the document, which evaluates the state-of-the-science of control banding as reflected in research and practice.

Among the conclusions, NIOSH indicates that control banding is a potentially valuable tool for risk management of some chemical agents and other occupational hazards; however, continued research and validation efforts are needed. Control banding is not meant to reduce the need for OELs but to serve as a supplemental risk management tool. If control banding is to be useful in the United States, NIOSH recommends in the draft document that the following actions occur:

  • Increase the awareness and standardization of control banding concepts;
  • Ensure validation of qualitative risk assessment and management strategies, tools, and the control-focused solutions;
  • Coordinate efforts for developing, implementing, evaluating, and disseminating qualitative risk assessment and risk management approaches to improve awareness and utility of task specific hazard control guidance;
  • Foster national and international coordination and collaboration in focusing on applications for control-focused solutions for high-risk tasks, industries, and small business enterprises;
  • Consider control banding models for broader applications to address additional workplace hazards (e.g., more complex chemical exposures, dermal exposure hazards, ergonomic hazards, and other physical hazards).

The draft document is posted for viewing until July 11. Public comments on the content of the draft document may be submitted in writing to Diane Miller at DMMiller@cdc.gov, or NIOSH Docket Office, Robert A. Taft Laboratories, 4676 Columbia Parkway, Mailstop C-34, Cincinnati, Ohio 45226.

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