Better Environmental Sustainability Targets (BEST)
Published by Occupational Knowledge International
|May 2016 - Volume 18|
OK International Publications
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The Back Story
A day earlier, Gottesfeld and David Jacobs (a Board member of OK International) attended the annual shareholder meeting of Sherwin Williams in Cleveland. We posed the same questions there and a protest was held outside this meeting with local media coverage. But Sherwin Williams was unmoved. The company is in the process of acquiring Valspar which also acknowledged to OK International that it continues to make lead paint.
A front-page story in the Washington Post, “A Dangerous Export,” described the impacts of lead battery recycling on workers and communities outside of Monterey, Mexico. The story points out that “While U.S. politicians express outrage over elevated lead levels in drinking water in Flint, Mich., they have done little to stem the flow of car batteries — each containing about 20 pounds of lead — south of the border.” The story is available online at this link: http://www.washingtonpost.com/sf/national/2016/02/26/a-dangerous-export-americas-car-battery-waste-is-making-mexican-communities-sick/
The U.S. Occupational Safety and Health Administration released its long awaited regulation on respirable silica updating the standard for the first time since 1971. The new standard sets a considerably lower Permissible Exposure Limit (PEL) of 50 ug/m3 (micrograms of silica per cubic meter) for airborne respirable silica and an Action Level of 25 ug/m3. The regulation mandates dust controls, restricted access and respirators above these levels. The rule is already under attack in Congress and has been challenged in court.
The preamble to the standard notes the link between silica exposure and Tuberculosis (TB) and the resulting increase in mortality among exposed workers in justifying these revisions to the silica standard. The concern regarding silica exposure as al risk factor for active TB underlines the need to control silica dust exposures in countries with high TB prevalence rates.
State regulators in California are struggling to test soil for lead contamination around 10,000 homes located within a 1.7 mile (2.7 KM) of the former Exide lead battery recycling plant in Vernon, CA outside Los Angeles. Earlier this year Governor Brown and the State Legislature provided $177 million in emergency funding to expedite the testing and cleanup around contaminated homes.
An analysis of blood lead levels in the community performed by the State Department of Public Health revealed that children within a one mile radius of the plant had a “moderate increase in risk” and were nearly twice as likely to have elevated blood lead levels than children throughout Los Angeles County.
The full report can be found here:
Nine years after OK International conducted the first large study of lead levels in new paints in India, the government released a draft regulation restricting the use of lead paint. The regulation for the first time prohibits the manufacture, trade, import and export of household and decorative paints exceeding 90 parts per million (ppm) lead. The regulation under the Ministry of Environment and Forests must now go through a comment period before being formally issued. The draft regulation is available at:
In January, Thailand issued its regulation for enamel paints sold for construction and decorative purposes restricting the lead content to 100 ppm. The regulation will take affect in January of next year. A link to the Thai standard can be found here:
We congratulate the efforts of our partners at EARTH (Thailand) and Toxics Link (India) on these achievements!!
OK International sponsored a session on Lead battery recycling at the United Nations International Conference on Chemicals Management (ICCM) in Geneva in October 2015. The Session “Lead Battery Recycling: Hazards and Opportunities for Improvement” was well attended by representatives from over 25 countries. Speakers at the session included Joanna Tempowski with the World Health Organization, Faridah Were with the Kenya Industrial Research and Development Institute, Eisaku Toda, with the UN Environment Programme, and Perry Gottesfeld with OK International.
One outcome of the session was to create a listserv network to coordinate future activities and actions to focus attention on this important global issue. Following the meeting OK International formally launched the Network on Lead Acid Battery Sustainability (NOLABS) among international partners seeking improvements in environmental sustainability throughout the life cycle of lead batteries. In addition, participants at this session have helped initiate a resolution under consideration at the UN Environmental Assembly on lead battery recycling for the session scheduled in Nairobi later this month. Anyone interested in joining the NOLABS network can send an email request to firstname.lastname@example.org.
The International Society of Environmental Epidemiology (ISEE) issued a “Call for Action for Global Control of Lead Exposure to Eliminate Lead Poisoning” which was published in the Journal Epidemiology in September 2015. (See http://journals.lww.com/epidem/Fulltext/2015/09000/Commentary___ISEE_Call_for_Action_for_Global.22.aspx) The statement calls on governments to take action to ban lead-containing fuels, paints, plumbing fixtures and plastics. It also called for more resources to investigate and reduce environmental lead contamination and to reduce occupational exposures and industrial emissions. Frank S. Rosenthal, Bruce P. Lanphear, Michal Krzyzanowski, and Perry Gottesfeld wrote the statement which was adopted by the ISEE Board.
The Board of Directors of the American Industrial Hygiene Association (AIHA) was asked to endorse the ISEE statement. In January the Board of Directors rejected this request stating that the since the purpose of the organization is to “support, protect and promote the membership of AIHA,” it will “not take a position to support a ban on the manufacture, sale, import, export or use of any product.”
Ironically, the substitution of materials had been considered a basic principle of industrial hygiene. In 1993, the AIHA stated in a position paper that "Pollution prevention and toxic use reduction (a group of activities under pollution prevention) are examples of fundamental industrial hygiene professional practices. . .[and]. . .if workers and the community can be protected from harm through prevention, this is preferred over other control measures."
OK International published the results of a study conducted to measure airborne silica exposures among small-scale gold miners in Tanzania. Although more than 75 published studies have reported on mercury exposures in and around artisanal gold mining, this was the first study to look at silica exposures in these operations. Our study showed that average exposures for underground drilling that were 674 fold greater than the American Conference of Governmental Industrial Hygienists (ACGIH) recommended Threshold Limit Value (TLV) and 28 fold greater for above ground operations. [Note the new OSHA 'Action Level' is equivalent to the TLV.]
It is estimated that there are 15 million artisanal miners in at least 70 countries around the world. These miners account for about 13% of the global gold production.
The article published in the Journal of Occupational and Environmental Hygiene is available via open access at this link: http://www.tandfonline.com/doi/pdf/10.1080/15459624.2015.1029617 “Silica Exposures in Artisanal Small-Scale Gold Mining in Tanzania and Implications for Tuberculosis Prevention.” Perry Gottesfeld, Damian Andrew & Jeffrey Dalhoff (2015) Journal of Occupational and Environmental Hygiene, 12:9,647-653.
In addition, Perry Gottesfeld published an article “Time to ban lead in industrial paints and coatings”, describing the literature on lead exposures documented in paint manufacturing, industrial applications and maintenance. It also addresses the ongoing effort by the European Union to ban the use of lead chromate pigments.
The article is available via open access in the Journal Frontiers in Public Health at this link:
In September 2015, the U.S. Environmental Protection Agency (EPA) released its proposed regulations on the export of used lead batteries from the U.S. The regulation addressed many of the flaws in the current regulations that OK International pointed out to the agency and to the Commission on Environmental Cooperation during its review of lead battery manufacturing in North America. Although the U.S. was supposed to follow the Organization for Economic Cooperation and Development (OECD) 2001 Guidelines for tracking these exports, we found that the agency failed to require some basic provisions of that standard. The new regulation calls for tracking individual waste shipments from origin to the ultimate recycling facility and requires electronic reporting of these exports.
The proposed rule may be found at the EPA web site at: https://www.epa.gov/hwgenerators/proposed-rule-hazardous-waste-export-import-revision