Occupational health professionals key to TSCA protections

Exposures to industrial chemicals and their health consequences remain a preventable source of occupational disease, with workers suffering more than 190,000 illnesses and 50,000 deaths annually related to chemical exposures, according to the U.S. Occupational Safety and Health Administration (OSHA). However, the occupational health community has not yet fully engaged with implementation of an important environmental statute, which is a missed opportunity to bolster the expertise of the U.S. Environmental Protection Agency (EPA), the agency charged to implement these newer legal authorities to protect workers at a systems level.

The Toxic Substances Control Act (TSCA) new authorities to protect worker health

The 2016 Frank Lautenberg Chemical Safety for the 21st Century Act amended Toxic Substances Control Act (TSCA) is a new tool for occupational health professionals to engage at the systems level for the protection of workers and their families from the myriad of harmful chemicals currently in use in the U.S. TSCA can help occupational health professionals to reduce exposures and is also dependent on these professionals for data to make TSCA more effective. We have published a commentary in Workplace Health & Safety: Promoting Environments Conducive to Well-Being and Productivity, the journal of the American Association of Occupational Health Nurses, on the importance of occupational health nurses (OHN) involvement in TSCA implementation.

More than 9.5 trillion pounds of 40,000+ industrial chemicals are currently in production according to the EPA, yet few are regulated in the workplace. Higher levels of environmental chemical exposures are often found in workplaces and nearby communities; these pollutants can harm worker’s health and the higher exposures in these groups can contribute to health inequalities. Workplace chemical exposures such as asbestos, methylene chloride, organic solvents, toxic metals, and halogenated flame retardants can increase the risk of death, cancer, birth defects and loss of cognitive capacity.

To address worker risks, the new TSCA authorities are an important part of a health-protective national policy because the law specifically names workers as a potentially exposed and susceptible subpopulation that EPA must evaluate as part of its risk evaluation process.

How occupational health professionals can engage with TSCA risk evaluations

Occupational health professionals can play a pivotal role in providing data about working conditions and health effects as well as advocating for health-protective evidence-based risk evaluation. OHNs can apply resources such as Vision Zero frameworks, OSHA’s Chemical Exposure Health Data (CEHD) and NIOSH’s Health Hazard Evaluation program. These occupational data should be better integrated into EPA’s risk evaluations and risk management approaches. Important opportunities for engagement include public comments on EPA’s prioritization, risk evaluations, and risk management phases.

Figure 1. OHNs can advocate for evidence-based, health-protective analytical techniques and occupational justice perspectives in the implementation of amended TSCA.

We encourage occupational health care providers to get more involved in TSCA implementation. To learn more, view PRHE materials describing key TSCA provisions or join the discussion on March 8th (Making TSCA Work). Occupational health providers can play an important role by providing data about conditions of use and advocating for health-protective safeguards under amended TSCA’s new authorities for those on the job.

Article: Toxic Substances Control Act (TSCA) Implementation: New Ways to Promote Occupational Justice and Prevent Worker Exposures From Hazardous Chemicals

Authors: Patricia D. Koman, Robyn Gilden, Nicholas Chartres, Tracey J. Woodruff.

About the authors

Robyn Gilden, PhD, RN, is an Associate Professor in the Department of Family and Community Health and the Director of the Environmental Health Certificate at the University of Maryland School of Nursing. She is a member of the American Public Health Association (APHA) Chemicals and Health Topic Committee and also on the Steering Committee of the Alliance of Nurses for Healthy Environments.

Trish Koman, PhD, MPP, has been an advocate for public health protection for over 25 years as a scientist at the U.S. Environmental Protection Agency and now the University of Michigan. Dr. Koman served as co-chair of the APHA Chemicals and Health committee and received the 2020 Distinguished Service Award from the APHA Environment Section.