User:Chase20092010/Control banding/SelahWillis Peer Review

'''Content added is up to date, relevant, and tone is neutral. I appreciate that you expanded on when control banding would be useful. I also like that you discussed an industry in which this approach would be especially necessary. The recommendations/comments I had are added in bold. They mainly involve adding or defining acronyms when they are used.'''

Control banding is particularly useful in circumstances where there are not established occupational or environmental exposure limits for a chemical. There are 219 million chemicals with a Chemical Abstracts Service (CAS) Registry Number[2], and less than 500 are regulated by the United States Occupational Safety and Health Administration (OSHA) [3]. Employers have a responsibility to protect their workers from harm regardless of whether a substance-specific standard exists, and control banding serves as a proactive approach to fulfilling this duty.

A single control technology or strategy is matched with a single band, or range of exposures (e.g. 1-10 milligrams per cubic meter) for a particular class of chemicals (e.g. skin irritants, reproductive hazards).

RISKOFDERM was a project funded by the EU to develop a toolkit to assess the adequacy of control measures in place to protect against substances which could cause adverse dermal effects (i.e. irritation, burns, sensitization)[4]

The toolkit was published in a paper version by the Instituto Nacional de Seguridad y Salud en el Trabajo in Spain[5]. It asks the user a series of questions regarding what substance is being used, how it is used, and what controls are already in place. The user’s answers will generate recommendations that vary from taking no additional action to stopping work immediately until the exposure can be reduced.

The OSHA regulations for respirable crystalline silica in construction utilize control banding to specify what controls employers must implement when working with materials that contain crystalline silica like concrete.

For example, when working outdoors with jackhammers that provide a continuous stream or spray of water at the point of impact, employers are required to provide industrial respirators if the work will take place over more than 4 hours in a single shift[6]. This qualitative method of implementing controls helps protect workers in environments that may vary day to day.

The use of control banding strategies has become very popular in the pharmaceutical industry[7] where early stage development compounds may have little or no toxicology data.

One control banding scheme in the pharmaceutical industry is proposed by Dr. Bruce Naumann[8]. It involves assigning a chemical a Merck Performance-Based Exposure Control Limit (PB-ECL) Category based on its toxicological properties and then based on that category using predetermined controls.

Below is a table which compares portions of this method to the one proposed by COSHH.

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