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Regulatory Alert (RA 00-17)

Member Pipeline - Regulatory - Alert (RA 00-17)

To: Members & Affiliates
From: National Office
Date: August 23, 2000
Subject: NIOSH HAZARD ID #10 - WORKERS EXPOSED TO CLASS B BIOSOLIDS
Reference: RA 00-17

NIOSH Acknowledges Inaccuracies of July 13 USA Today Article in Letter to AMSA
In an August 14, 2000 letter sent to both AMSA and Water Environment Federation from NIOSH Chief of Staff Dr. Marilyn Fingerhut, the Agency admits that USA Today's July 13, 2000 story on biosolids "inaccurately relates the Hazard ID #10: Workers Exposed to Class B Biosolids During and After Field Application to environmental issues surrounding biosolids and incorrectly suggests that the NIOSH document evaluates the EPA biosolids program." The NIOSH response and admission comes as a direct result of an August 10 meeting arranged by AMSA and WEF. Both organizations took exception to the content and timing of the widely publicized and incorrect USA Today article.

On July 28, the National Institute for Occupational Safety & Health (NIOSH) released a report titled, NIOSH Hazard ID #10: Workers Exposed to Class B Biosolids During and After Field Application which provides recommendations to workers for preventing illness associated with exposure to Class B biosolids (see attached). The report establishes recommendations for personal protective equipment, proper hygiene and sanitation, hazard communication and training, and engineering controls to reduce worker risks while handling Class B biosolids. Issuance of the report was preceded by the July 13 USA Today article which incorrectly linked the report to the adequacy of EPA’s sludge program.

On August 10, AMSA and representatives of the Water Environment Federation (WEF) met with officials from the National Institute for Occupational Safety and Health (NIOSH) to share concerns regarding the issuance of NIOSH’s July 28 report. AMSA and WEF expressed several concerns with the Hazard ID’s development process, overly-broad recommendations, and other circumstances surrounding the report’s release. AMSA also informed NIOSH of the serious impacts the Hazard ID has already had upon public wastewater treatment agencies, citing recent moves by legislators and other interests who have used the report to support calls to ban the land-application of Class B biosolids.

 AMSA and WEF noted the flaws inherent in NIOSH’s Hazard ID process because it excluded a review by industry experts and relied upon a hazard review of one facility. Problems were noted with NIOSH’s broad recommendations to establish engineering controls which reduce worker risks, including recommendations to minimize storage time of Class B materials and requiring soil incorporation. The recommendations fail to adequately account for site-specific factors. It was emphasized that by not accounting for varying methods for treating biosolids, the recommendations may conflict with safe biosolids handling procedures already in place. NIOSH officials expressed interest in AMSA and WEF’s concerns and requested a detailed letter delineating areas in which the report can be improved. Based on these specific comments NIOSH officials said they would consider revising the existing Hazard ID. AMSA and WEF have formed a small workgroup to draft a set of formal recommendations for revising the Hazard ID, which will be transmitted to NIOSH later this month.

 

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