Our very own Mark Katchen worked with Rob Agnew and Anant Bhan to create a framework for international industrial hygiene ethics, released last week on The Synergist.
An 8-step decision-making framework is provided to the ethical considerations surrounding a methylene chloride example that begins the article. As with many dilemmas in industrial hygiene, this example revolves around the precautionary principle, a doctrine that supports application of the most restrictive regulation or most protective standard.
Here are the first three steps:
Step 1: Gather facts. Methylene chloride has an OSHA Permissible Exposure Limit of 25 ppm, a U.K. Workplace Exposure Limit of 100 ppm, and a German MAK of 50 ppm. The ACGIH Threshold Limit Value is 50 ppm. The company wishes to act ethically and would not violate the law in any country. Therefore, the baseline of compliance is the local exposure limit where each facility operates.
Step 2: Review the standards for ethical industrial hygiene practice. The standards that apply are the ABIH Code of Ethics (PDF).
Step 3: Articulate the ethical concern. If the company merely complies with the local law, it will be treating employees differently with respect to disease risk, which presents an ethical dilemma involving justice and the right to a healthy workplace.
To start a free 30-day subscription to receive important regulatory updates about what’s going on in your industry with all of your peers, click here.