Relevance of Exposure Data to Regulatory Impact Analyses: Overcoming Availability Problems

Abstract

Beyond the workplace, exposure databases play an important role in regulatory policy making. They are key elements in analyses that characterize baseline exposures, estimate feasible reductions in exposures or hazards, and estimate the costs to be incurred in implementation of Occupational Safety and Health Administration (OSHA) regulations. The need for regulatory impact assessments is created by executive orders, as well as congressional and judicial actions which require federal agencies to evaluate the impact of proposed regulations. In this article three examples of recent regulatory analyses are presented to illustrate the procedures used to integrate exposure data. The studies are: permissible exposure limits (PELs) in general industry, PELs in construction, and lead in construction. Some of the information commonly used by OSHA was created for other purposes: inspection and enforcement, control strategy evaluation, epidemiological research, or risk assessment. Even though the exposure data in some cases may be available in sufficient quantity to allay bias fears, they may be inadequate for a regulatory analysis because information about the conditions under which the exposures occurred may be incomplete. To learn more about the circumstances under which exposures or hazards occur and other baseline data, OSHA, at great expense, commissions surveys of the firms affected by the proposed regulation, sponsors site visits to observe worker activities and gather exposure data, and conducts interviews with industry experts and specialists. The need for a national exposure data bank is critical. The process of regulatory analysis would be improved considerably if exposure data were enhanced with clearly identified, inclusive industry coverage. The data sources should carefully describe the circumstances and conditions that produce, influence, or explain the exposure point value. The description of processes and activities must follow a consistent taxonomy to allow comparisons across multiple sources of data. The financial and economic dimensions of regulatory action are dependent upon the nature of the exposure conditions found in the workplace. Once these are documented, regulatory economic analysis can be done expeditiously and economically. Botkin, A.; Conway, H.: Relevance of Exposure Data to Regulatory Impact Analyses: Overcoming Availability Problems. Appl. Occup. Environ. Hyg. 10(4):383–390; 1995.