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Here you will find an
archive of previous articles relating to health care and safety.

Microwave & Radio Frequency Radiation
Since World War II, many significant technological advancements have occurred
within the telecommunications and other industries. One of these is the
increased use of radio frequency, i.e., microwave and radio wave radiation
equipment. Such equipment is widely used in the broadcasting and communications
fields in the form of cellular telephones and towers; in the health care
industry for medical treatment; in the food industry for the processing and
cooking of food; in the wood, textile, and glass fiber industries for drying
materials; and in the automotive, electrical, rubber, and plastic products
industries for fusing and sealing operations.
The National Institute for Occupational Safety and Health (NIOSH) estimates that
millions of American workers work with and are exposed to radio frequency
radiation equipment. CWA members who are exposed to radio frequency radiation
include telecommunications microwave and radio wave service technicians and
outside plant technicians, operators of computers, employees who use microwave
ovens at work, radio frequency radiation equipment operators, manufacturing
workers, and workers who come in contact with or who operate medical diathermy
equipment.
Radio frequency, i.e., microwave and radio wave radiation, is a specific
component of the electromagnetic spectrum. Radio frequency radiation is in the
non-ionizing portion of the spectrum. Non-ionizing radiation includes the lower
frequencies in the electromagnetic spectrum such as ultraviolet and visible
light, infrared, microwave and radio wave (See Table I).

Electromagnetic radiation consists of vibrating electric and magnetic energy or
fields moving through space. For example, electric current in a transmitter
circuit establishes electric and magnetic fields in the region around it. As the
electric current moves back and forth, the fields continue to build up and
collapse, forming electromagnetic radiation. This electromagnetic radiation is
characterized in terms of the wavelength and the frequency of vibration.
Microwave and radio wave radiation may be categorized as continuous waves (e.g.,
communications equipment), intermittent (microwave ovens, medical diathermy
equipment, and radio frequency equipment), or pulsed mode (radar systems).
Microwave and radio frequency radiation may be transmitted, reflected, or
absorbed upon striking an object.
When measuring radio frequency radiation emissions, the power of the source
should be measured by the intensity of the field. Intensity should be measured
in terms of power density. Power density is the amount of energy carried by
radio frequency, i.e., microwave or radio wave, radiation as it proceeds each
second through a square measure of space. The energy carried by microwave and
radio wave radiation is expressed in terms of milliwatts per square centimeter (mW/cm
(2) = 1/1,000 of a watt) or microwatts per square centimeter (uW/cm (2) =
1/1,000 of a milliwatt).
Health Effects
The various types of radiation affect the human body in different ways. For
example, ionizing radiation, that contains a tremendous amount of energy and
penetrating power, will cause changes in the body's molecular system. On the
other hand, as noted, non-ionizing radiation operates at much lower frequencies
and is not believed to be as harmful to the human body as ionizing radiation.
The type of radiation to which affected CWA members are most often exposed is
non-ionizing radiation, e.g., radio frequency, i.e., microwave and radio wave,
radiation.
It is known, however, that exposure to non-ionizing radio frequency radiation
may produce serious biological effects. As high frequency radio frequency
radiation, i.e., microwave radiation, penetrates the body, the exposed molecules
move about and collide with one another causing friction and, thus, heat. This
is known as thermal effect. If the radiation is powerful enough, the tissue or
skin will be heated or burned. Such health effects may or may not be reversible,
depending on the particular tissue or organ that is exposed, the intensity of
the radiation, the frequency and duration of the exposure, the environmental
temperature and humidity, and the body's efficiency in dissipating the heat.
At the present time, there is substantial scientific data that establishes
negative health effects associated with microwave radiation. For example, it has
been demonstrated that microwave radiation may cause eye and testicular damage.
These organs are highly vulnerable to radiation damage because they contain few
blood vessels. Therefore, they are unable to circulate blood and dissipate the
heat from radiation as effectively as other organs.
An additional health concern involves damage to the eyes. For example, several
scientific investigations have shown that cataracts among humans and laboratory
animals have occurred as a result of the intense heating of high frequency
microwave radiation. Such data has revealed that a particularly important
determinant in the causation of microwave radiation-induced cataracts is the
time intervals between exposures, i.e., increased time intervals between
exposures is thought to allow the body's repair or defense mechanism more
opportunity to limit ocular lens damage.
As noted, microwave radiation may also cause damage to the male
testes/reproductive organs. Specifically, scientists have demonstrated that
exposure to microwave radiation may result in partial or permanent sterility. In
addition, some scientific evidence suggests similar effects associated with
microwave exposure and female reproductive problems. Furthermore, the scientific
literature indicates a relationship between exposure to microwave radiation and
birth defects, such as mongolism (Down's Syndrome) and central nervous system
damage.
Exposure to radio wave radiation may result in a non-thermal reaction that
causes similar molecular interactions as in the thermal effect, but without the
heating of the exposed tissue or organ. The site of energy absorption varies
with the frequency, that is, exposure to low frequency non-ionizing radio
frequency radiation will (theoretically) penetrate the skin and cause molecular
interactions similar to those caused by high frequency radio frequency
radiation. Complicating such non-thermal reaction, the body's heat and warning
system may not provide protection because the energy is absorbed at locations
below the nerves.
Clearly, a review of the medical and scientific literature indicates a
tremendous need for more scientific research. Such research should focus upon
the effects of microwave and radio wave radiation upon humans. Particular
emphasis needs to be directed at exposure to long-term, low-level biological
effects of microwave and radio wave radiation. Such research is particularly
important in order that the issue of exposure to potentially harmful microwave
and radio wave radiation emissions from microwave and radio wave transmitters
and human health effects might be more adequately determined.
An additional health concern regarding work with radio frequency equipment is
potential electrical shock. This may occur when, under abnormal conditions, the
operator is standing in water and comes into contact with a high-frequency
generator circuit.
Controlling the Hazard
Employers must ensure that potentially exposed microwave and radio wave
radiation workers have a safe and healthful workplace. This means that employers
should implement engineering controls to minimize or eliminate potential
exposure, conduct comprehensive training about the potentially hazardous working
conditions, and institute medical surveillance programs.
The most effective way to eliminate and/or minimize occupational exposure to
radio frequency microwave and radio wave radiation is through the use of
engineering controls. For example, the source of the potential problem, i.e.,
the radiation-emitting equipment, should be enclosed or effectively shielded or
the worker should be separated from the source. This requirement is equally
important to all workers exposed to microwave and radio wave radiation. Where
engineering controls cannot be implemented, personal protective equipment such
as protective clothing and eyewear should be provided and utilized.
In addition, employers should provide comprehensive training regarding
potentially hazardous working conditions. Such a program might consist of
written and/or audio/visual materials that detail potential safety and health
dangers, health effects of exposure, methods of control, first aid procedures,
the use of hazard warning signs and labels, and the identification of restricted
areas.
Employers should also institute medical surveillance programs that would provide
workers with routine medical examinations specific to any biological effects
resulting from occupational radio frequency radiation exposures. Potential
benefits of medical surveillance would include: an assessment of employees'
physical fitness to safely perform the work (consisting of a medical and
occupational history as well as a physical examination), biological monitoring
of exposure to a particular agent, and early detection of any biological damages
or effects. In addition, documented health effects would allow the worker and
her/his physician to make informed judgements about further exposures.
The OSHA Standard
The OSHA Standard for electromagnetic radiation (that does not cover low
frequency radio frequency microwave or radio wave radiation) is 10mW/cm(2) (milliwatt
per square centimeter) as averaged over any possible 0.1 hour period. This means
the following:
Power Density: 10mW/cm(2) (milliwatt hour per square centimeter) for periods of
0.1 hour or more.
Energy Density: 1mW/cm(2) (milliwatt hour per square centimeter) during any 0.l
hour period.
The Standard is based upon research conducted in 1953 examining the threshold
for thermal (heat) damage to tissue. (Specifically, the amount of radiation that
would cause cataract development). The power density necessary to produce
cataracts was approximately 100 mW/cm(2) to which a safety factor of 10 was
applied. Thus, a maximum permissible level of 10mW/cm(2) was established.
Unfortunately, as noted, the OSHA Standard does not provide coverage for low
frequency radio frequency microwave and radio wave radiation. Therefore, given
concerns among involved scientists and practitioners, three non-governmental
organizations, e.g., the American National Standards Institute (ANSI) and the
Institute of Electrical and Electronics Engineers (IEEE), as well as the
National Council on Radiation Protection and Measurements (NCRP), developed and
issued two different voluntary guidelines on radio frequency microwave and radio
wave radiation. In turn, in 1996 the Federal Communications Commission has
translated these voluntary guidelines into recommended exposure criteria (See
Table II).

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In This Chapter |
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The Occupational Safety and Health Administration (OSHA)
administers the employee protection (or "whistleblower") provisions of fourteen
statutes.
Occupational Safety & Health Act (OSH Act), 29 USC § 660(c)
Surface Transportation Assistance Act (STAA), 49 USC § 31105
Asbestos Hazard Emergency Response Act (AHERA), 15 USC § 2651
International Safety Container Act (ISCA), 46 USC App. § 1506
Energy Reorganization Act of 1974 (ERA), 42 USC § 5851
Clean Air Act (CAA), 42 USC § 7622
Safe Drinking Water Act (SDWA), 42 USC § 300j-9(i)
Federal Water Pollution Control Act (FWPCA), 33 USC § 1367
Toxic Substances Control Act (TSCA), 15 USC § 2622
Solid Waste Disposal Act (SWDA), 42 USC § 6971
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
42 USC § 9610
Wendell
H. Ford Aviation Investment and Reform Act (AIR21), 49 USC § 42121
Sarbanes-Oxley Act (SOA), 18 USC § 1514A
Pipeline Safety Improvement Act (PSIA), 49 USC § 60129
Under the OSH Act, employees who believe that their employer has
discriminated or retaliated against them for raising or reporting safety or
health concerns may file a complaint with OSHA. Under the STAA, employees in the
trucking industry may file complaints with OSHA if they believe that their
employer has discriminated against them for reporting safety concerns or for
refusing to drive under dangerous circumstances or in violation of safety rules.
Similarly, under the other statutes, employees also may file complaints with
OSHA if they believe that their employer has discriminated against them for
reporting protected safety concerns involving the airline or pipeline
industries, for reporting protected environmental concerns including asbestos in
schools, or for reporting potential securities fraud.
The Department of Labor also enforces the anti-retaliation provisions of
several other statutes that are not administered by OSHA. Information concerning
many of these additional anti-retaliation statutes is available in other
sections of the Guide describing the statutes enforced by different
Department agencies, such as the Wage and Hour Division, the Employee Benefits
Security Administration, and the Mine Safety and Health Administration.
Generally, the employee protection provisions listed above prohibit an
"employer" or any "person" (the definition of which may vary from statute to
statute) from discharging or otherwise discriminating against any employee with
respect to the employee's compensation, terms, conditions, or privileges of
employment because the employee engaged in specified "protected" activities.
The protected activities typically include: (1) initiating a proceeding
under, or for the enforcement of, any of these statutes, or causing such a
proceeding to be initiated; (2) testifying in any such proceeding; (3) assisting
or participating in any such proceeding or in any other action to carry out the
purposes of these statutes; or (4) complaining about a violation.
The ERA, the AIR21, the SOA, and the PSIA specifically cover an employee's
internal complaints to his or her employer, and it is the Secretary's position,
as set forth in regulations, that employees who express safety or quality
assurance concerns internally to their employers are protected under the other
whistleblower statutes. With the exception of the Fifth Circuit, the courts of
appeals that have considered whether internal complaints are protected have
agreed with the Secretary.
An employee who believes that he or she has been discriminated against in
violation of any of the statutes listed above may file a complaint with OSHA.
Complaints must be filed within 30 days after the occurrence of the alleged
violation under the OSH Act, the CAA, the CERCLA, the SWDA, the FWPCA, the SDWA,
and the TSCA; within 60 days under the ISCA; within 90 days under the AIR21, the
SOA, and the AHERA; and within 180 days under the STAA, the ERA, and the PSIA.
Under the SOA, if the Secretary has not issued a final decision within 180 days
of the filing of the complaint, and there is no showing that there has been
delay due to the bad faith of the employee, the employee may bring an action at
law or equity in district court.
More detailed information, including copies of regulatory and interpretative
materials, may be obtained from the nearest OSHA office. Addresses and telephone
numbers for these offices are set forth in local directories and on
OSHA's Web site.
Upon receipt of a timely complaint, OSHA notifies the employer and, if
conciliation fails, conducts an investigation. Where OSHA finds that complaints
filed under the OSH Act, the AHERA, and the ISCA have merit they are referred to
the Solicitor's Office for legal action. Complaints under these three statutes
found not to have merit will be dismissed.
Where OSHA finds a violation after investigating complaints under the other
statutes listed above, it will issue a determination letter requiring the
employer to pay back wages, reinstate the employee, reimburse the employee for
attorney's and expert witness fees, and take other steps to provide necessary
relief. Complaints found not to have merit will be dismissed.
Parties who object to OSHA's determinations under the statutes listed above
(except for the OSH Act, the AHERA, and the ISCA) may request a hearing before
the Department of Labor's Office of
Administrative Law Judges (OALJ). Judges' decisions are reviewed by the
Department of Labor's Administrative Review
Board, which the Secretary has designated to issue final agency decisions.
Under the STAA, if OSHA finds in favor of the employee, litigation usually is
conducted by the Solicitor's Office, but sometimes by the employee. Under the
other statutes, litigation generally is conducted by the private parties
themselves. Employers and employees may seek judicial review of an adverse ARB
decision.
Under the AIR21, the SOA, and the PSIA, employees who file complaints
frivolously or in bad faith may be liable for attorney's fees up to $1,000.
The Supreme Court has held that the employee protection provisions of the
Energy Reorganization Act do not preempt existing state statutes and common law
claims. The other statutes listed above should be consulted separately to
determine whether or not their employee protection provisions are supplementary
to protection provided by state laws.
| The Employment Law Guide is offered as a
public resource. It does not create new legal obligations and it is not a
substitute for the U.S. Code, Federal Register, and Code of Federal
Regulations as the official sources of applicable law. Every effort has been
made to ensure that the information provided is complete and accurate as of
the time of publication and this will continue. Later versions of this Guide
will be offered at
www.dol.gov/compliance or by calling our toll-free service at
1-866-4-USA-DOL (1-866-487-2365). |
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Lasers & the Workplace
Many products of post-World War II technology have been widely implemented
within the United States. Several of these innovations have occurred within the
telecommunications and health care industries. One such product is the laser.
Although initially developed during the 1950's, laser equipment, in particular,
laser-based fiber optic equipment and medical devices have only recently been
introduced into the telecommunications, health care, and manufacturing
industries. Within the telecommunications industry, CWA members should expect to
see lasers in the form of fiber optic cables introduced at an increasing rate
due to the fact that laser equipment can carry many more communications messages
and require less maintenance than lead and polyurethane-encased cables. In the
health care field, laser medical devices are being widely introduced and used
for enhanced medical treatment. In manufacturing, lasers are frequently used in
welding, cutting, and sealing operations. Union members also utilize laser
equipment in medical micro-machinery, optical alignment, surveying, and writing
operations.
CWA members employed as telecommunications installers, outside plant
technicians, cable splicers, service technicians, manufacturing workers, and
medical workers who use laser components or test equipment may be exposed to
potentially hazardous laser equipment. In addition, members working at
construction sites should be careful that they do not enter the path of a laser
beam.
Laser means light amplification by stimulated emission of radiation. Lasers
produce visible and invisible (ultraviolet and infrared) radiation in the
non-ionizing portion of the electromagnetic spectrum. Lasers are made up of
electromagnetic waves of the same wavelength and frequency that travel in one
direction and are monochromatic (one color). Thus lasers are referred to as
coherent light.
There are three types of laser beam generating media: solid state, gaseous
state, and semi-conductor. Solid state lasers are used in such operations as
tunneling and mining. The most common type of solid state laser is the ruby
crystal. Gaseous state lasers, such as a helium neon laser, are most widely
utilized in the construction industry for the purpose of establishing a
reference line for dredging, tunneling, pipe laying, bridge building, and marine
construction equipment. Semi-conductor lasers are most widely used in the
transmission of communications signals. Because of the inability of
semi-conductor laser beams to penetrate fog, rain, or snow very well, they are
enclosed within telecommunications cables. In addition, solid state and gaseous
state laser technology is widely utilized within the health care and
manufacturing industries.
Lasers are categorized into five different classifications: Class I, Class II,
Class III-a, Class III-b, and Class IV. These classifications reflect the
ability of the laser beam to cause damage to the eyes or skin with Class I
categorized as the least hazardous and Class IV the most hazardous. Class I
lasers do not emit hazardous levels of radiation under normal operating
conditions. (However, direct eye exposure should be avoided.) Therefore, they
are ruled to be exempt from guidelines established by the U.S. Center for
Devices and Radiological Health (CDRH) and the American National Standards
Institute (ANSI), a non-governmental organization involved in developing
occupational safety and health standards.
Class II lasers are low-power devices that do not produce enough power to injure
a person except when the source of the laser is stared at for a lengthy period.
CDRH regulations require that employers put a caution label on Class II
equipment.
Class III-a lasers include (visible) lasers that cannot cause injury to the
unprotected eye except when viewing the laser with magnifying equipment such as
a microscope. CDRH requires that a caution label be affixed to Class III-a
lasers.
Class III-b laser equipment emits radiation that can cause injury to the eye if
viewed directly or from a reflected beam. As with Class II and Class III-a
lasers, caution labels must be displayed upon Class III-b laser equipment.
Technically, laser equipment that is used for telecommunications transmissions
is categorized as Class III-b. However, since under normal operation the laser
beam is totally enclosed and protected, the CDRH classifies such equipment as a
Class I laser system and, thus, is exempt from CDRH regulations. Of importance,
when lightguide or laser telecommunications cables become disconnected or
broken, they should be considered as Class III-b.
Class IV lasers produce radiation that may cause eye damage by direct viewing
and/or from reflections. In addition, Class IV lasers may present a fire hazard.
Thus where possible, the laser beam path should be controlled. When the beam
path is not enclosed, a safety latch or interlock system should be used. Such a
system would prevent operation unless the laser equipment is furnished with the
proper enclosures. Class IV lasers must have a warning label affixed to them.
Health Effects
Lasers and laser equipment may be potentially hazardous to the eyes and skin.
The degree of risk depends upon the type of laser beam, the frequency or power
of the laser, beam divergence, as well as the intensity and duration of
exposure.
The eye is the most susceptible to damage from laser radiation. Upon exposure,
the cornea and the lens of the eye (located at the front of the eye) magnify and
focus the radiation on the retina (located at the back of the eye). Direct
exposure to a laser beam or a reflection of a laser beam may burn the retina
causing partial or complete blindness. When a worker suffers eye damage, she/he
should have an eye examination as soon as possible. Factors determining the
amount of damage to the eye include the reaction of the cornea and lens, the
presence or absence of reflective materials between the laser source and the
eye, and the distance from the laser to the retina.
When working with lasers or laser equipment, optical aids like microscopes and
binoculars should not be used (unless beam intensities are so low as to be
absolutely safe). This practice should be followed because such optical aids
serve as magnifiers of the laser beam, thus increasing the intensity of the
beam.
Skin exposure to laser radiation may cause mild reddening and swelling,
blistering, or charring. The degree of harm is dependent upon the duration of
exposure, radiation wavelength, and the amount of radiation absorbed.
In addition, the health hazard of electrical shock exists when CWA members are
working with high voltage laser transmission components. Highly powered lasers
also set off electrical discharges into the atmosphere, emitting ozone.
Hazardous exposure to ozone may result in eye and upper respiratory irritation.
CWA members employed as light guide manufacturing workers are exposed to several
unique and potentially hazardous working conditions. Not only do these employees
encounter safety and health hazards associated with lasers, i.e., potential
damage to the eyes and skin, they are also exposed to a variety of toxic
chemicals and solvents, broken glass, electrical hazards, hazards associated
with working on ladders and platforms, radio frequency radiation hazards,
substances that can cause severe burns, and potential air contaminant hazards
from chemical spills. Manufacturing employees who work directly with laser
equipment should not look directly into the laser beam or reflection beam. Such
exposure may result in partial or total blindness. Employers should ensure that
manufacturing workers are provided with the necessary safeguards to ensure that
all potential harmful exposures may be minimized/eliminated.
Controlling the Hazard
Laser hazard controls should be designed to eliminate or minimize potential eye
hazards resulting from a direct laser beam or a reflection of the beam, as well
as skin burns. Employers should utilize proper engineering controls to
minimize/eliminate harmful occupational exposures. Engineering controls may
depend on whether the laser equipment is used in or out-of-doors. As required,
backstops and shields should be utilized to protect workers from possible
exposure.
Employees should also be provided with necessary personal protective equipment
such as gloves, eyewear, and clothing. Warning signs should be affixed to laser
equipment that indicate the type of laser and potential eye and skin hazards.
All surfaces in the laser area should be non-reflective and the work area should
be brightly lit to prevent the dilation of the pupils. All flammable materials
should be stored in proper containers and shielded from the laser beam. All
electrical hazards should be safeguarded. Where possible, audible signals should
be used to indicate when the laser equipment is in operation. Employers should
also establish and maintain effective maintenance programs.
In addition, employers must provide CWA members who operate and/or are exposed
to laser equipment with comprehensive training and education detailing the
potential hazards of lasers. Only trained personnel should work with or near
laser equipment.
Employers should establish a medical surveillance program for all CWA members
working with or around laser equipment. Such a program would consist of a
pre-placement medical examination that should include opthamologic (eye) and
dermatologic (skin) tests as well as a review of the worker's medical and work
history. Information obtained from these medical examinations would allow for
accurate detection and documentation of medical problems. Also, medical
information and test results should be made available to all employees upon
request.
OSHA's Laser Standard
Except for the construction industry, OSHA does not presently have a standard
for lasers. However, CDRH regulations contain a series of control measures for
Classes I - IV lasers. Included in the regulations are requirements such as
proper eye protection, protective laser filters, limitations for eye and skin
exposure, and visible and audible warning indicators. (A copy of the guidelines
can be obtained by contacting the CWA Occupational Safety and Health
Department).
In addition, ANSI has set recommended maximum permissible exposure levels for
lasers. These guidelines should be used to determine hazardous exposure levels.
(A copy of the guidelines can be obtained by contacting the CWA Occupational
Safety and Health Department).
Since OSHA does not have a laser standard for General Industry work, it would
refer to the CDRH and ANSI guidelines when investigating potential overexposure.
Therefore, CWA members should use these guidelines to determine and prevent
hazardous work operations.
What Can You Do?
All CWA members should make sure that their employer is maintaining a safe and
healthful workplace. The key to making the workplace safe for all CWA members is
strong, active, local safety and health committees. The committee can identify
dangerous conditions at the workplace and discuss them with management. If the
employer refuses to cooperate, the committee can request an OSHA inspection. The
committee should always coordinate its activities through the local officers,
the CWA Representatives, and negotiated safety and health committees.
In addition, CWA members may obtain information and assistance by contacting
the:
CWA Occupational Safety and Health Department
501 Third Street, NW
Washington, D.C. 20001-2797
Webpage: www.cwasafetyandhealth.org
Phone: (202) 434-1160.
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Right to Refuse Unsafe Work
Thousands of workers die or are injured because of on-the-job accidents each
year. Many more are exposed to unhealthy conditions that cause serious illnesses
years later.
When does a worker have the right to refuse dangerous work?
On February 26, 1980, the United States Supreme Court issued a landmark ruling
which more clearly defined a worker's right to refuse work where an employee(s)
has (have) reasonable apprehension that death or serious injury or illness might
occur as a result of performing the work. The unanimous decision came in a 1974
case against Whirlpool Corporation in which two workers refused to crawl out on
a screen from which a co-worker had fallen to his death only nine days earlier.
A Cincinnati, Ohio appeals court ruled in favor of the worker's rights in
"Whirlpool" and the Supreme Court affirmed that decision. (At the time
the Supreme Court took the Whirlpool case, there were two other appeals court
rulings that had been decided the opposite way. These cases were issued by
courts in New Orleans (1977) and Denver (1978).
The two workers in the "Whirlpool" case were told to go out on a
screen 20 feet above the floor to retrieve small appliance parts which had
fallen from a conveyor belt system above. The screen was in place to protect
workers in the plant from falling parts. The retrieval assignment had resulted
in other workers falling partially or completely through the screen. Claiming
that the screen was unsafe, two employees refused to carry out the assignment.
Whirlpool supervisors sent the workers home for the day and withheld about six
hours pay.
In its decision, the court emphasized that the OSHAct provides a worker with the
right to choose not to perform an assigned task due to reasonable apprehension
of death or serious injury coupled with a reasonable belief that no less drastic
alternative is available. Further, the Court held that a worker who utilizes
this OSHAct protection may not be discriminated against for such action.
However, the Court also indicated that an employee who refused work based on the
regulation runs the risk of discharge or reprimand in the event a court
subsequently finds that she/he acted unreasonably or in bad faith.
As noted, the employer docked the two workers about six hours pay in the
Whirlpool case. The Supreme Court ruled that the OSHAct does not require an
employer to pay a worker who refuses to perform an assigned task in the face of
imminent danger. Rather, the Act simply provides that in such cases the employer
may not discriminate against the involved worker(s). Thus, the Court has left
this issue to be decided by labor and management through collective bargaining.
Members of unions that do not negotiate the necessary protective language in
their contracts should not expect to be paid for the refusal to work period.
This will be true even where an employer is found guilty of violating the OSHAct.
In light of the Supreme Court's decision, what should CWA members who are
faced with an imminent danger situation do?
The Supreme Court has said that a worker may refuse unsafe work where she/he has
refused the job in good faith. Good faith may be interpreted as an honest belief
that the job was unsafe and unusually and objectively dangerous.
Good faith can be demonstrated by the manner by which you refuse unsafe work:
 | Explain the hazard to the supervisor and your steward,
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 | Offer to do other, safe work until the hazard is corrected,
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 | Give management a chance to respond before doing anything else,
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 | If the condition isn't corrected, call OSHA and request an "imminent
danger" inspection,
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 | Do not walk off the job. If management won't fix the hazard, force them to
take the next step. Make sure you have expressed your reasons for refusing
the job and your willingness to do other work, clearly and in the presence
of your steward and/or other workers.
If you're fired or disciplined:
|
 | File a grievance immediately,
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 | File an unfair labor practice charge with the NLRB immediately but within
180 days, and
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 | File a Section 11(c) discrimination complaint with OSHA immediately but
within 30 days.
The bottom line is to stay cool. Don't let management provoke you into rash
action that could hurt your case later.
Proving that your job was "abnormally and objectively dangerous"
is a matter of documentation:
|
 | Was the job one you'd never done before? Or, had the conditions of the job
changed recently?
|
 | Did you protest the job before?
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 | Did other workers protest the job before? Did others refuse to do the job?
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 | Was the company in violation of OSHA, state, or local safety and health
regulations?
|
 | Many chemicals and conditions are clearly dangerous but aren't covered by
any standards. Have workers been injured or made sick doing your job? Just
what chemicals were you working with?
If any CWA member refuses unsafe work, she/he should notify the local union
president. In turn, this information should be made available to the CWA
Representative and the CWA Occupational Safety and Health Department.
What Can You Do?
All CWA members should make sure that their employer is maintaining a safe
and healthful workplace. The key to making the workplace safe for all CWA
members is strong, active local safety and health committees. The committee
can identify dangerous conditions at the workplace and discuss them with
management. If the employer refuses to cooperate, the committee can request
an OSHA inspection. The committee should always coordinate its activities
through the local officers, the CWA Representatives, and negotiated safety
and health committees.
In addition, CWA members may obtain information and assistance by contacting
the:
CWA Occupational Safety and Health Department
501 Third Street, N.W.
Washington, D.C. 20001-2797
Webpage: www.cwasafetyandhealth.org
Phone: (202) 434-1160. |
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Polyurethanes and Isocynates and the
Workplace
Polyurethanes are a creation of America's post World War II science and
technology--a period when hundreds and thousands of so called "wonder
chemicals" were invented. Polyurethanes or plasticizers are produced in
three forms:
 | As flexible or soft foams used primarily for cushioning;
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 | As rigid foams used primarily for building insulation, support elements,
and decoration, and;
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 | As elasto-plastics used for automobile body panels, coatings, adhesives,
sealants, and as a substitute for rubber. Because of ease of application and
versatility, manufacturers and employers consider polyurethanes to be
invaluable.
Polyurethanes are formed by combining a variety of chemicals. The most
important ingredient is the family of isocyanates. The family of isocyanates
includes: Toluene Diisocyanate (TDI), Methylene Bisphenyl Diisocyanate
(MDI), also known as Diphenyl Methane Diisocyanate, Hexamethylene
Diisocyanate (HDI), Naphthalene Diisocyanate (NDI), and Diisocyanate
Dicyclohexyl Urethane.
Several thousand CWA telecommunications and automotive manufacturing members
work with and are exposed to isocyanate products. In the telecommunications
industry, this work involves the use of polyurethane products used as (foam)
plugs to weatherproof and seal telephone cable splices and, in the
automotive manufacturing industry, polyurethane products are used in the
manufacturing of plastics and related materials.
Health Effects
Although all of the isocyanate products are hazardous, Toluene Diisocyanate
(TDI) is considered the most toxic. Therefore, this section of the fact
sheet will focus primarily upon the health effects associated with exposure
to TDI. However, CWA leaders and members should assume that exposure to
other isocyanate products may cause the same or similar health problems.
TDI irritates all living tissues that it comes in contact with. TDI vapors,
which may be emitted when mixing the two chemical mixtures (or A and B
ingredients), may be inhaled or breathed. Inhalation of such vapors can
produce severe irritation and burning to the mucous membranes of the eyes
and respiratory tract. Inhalation may also cause nausea, vomiting, abdominal
pain, and breathing problems. In addition, skin contact can cause a rash
commonly referred to as contact dermatitis. Of particular concern, the
National Institute for Occupational Safety and Health (NIOSH) has identified
TDI as a (animal) carcinogen.
TDI exposure causes serious upper respiratory health problems-involving the
nose, throat, esophagus, and lungs. Also, TDI can cause acute irritation,
chronic irritation, and sensitization of the lungs and throat. Acute
irritation is like a burn inside the nose, throat, or lungs. The throat and
lungs become so damaged by TDI that the body loses its ability to defend
against infections. Such acute irritation may cause the lungs to become
filled with fluid. In turn, this condition could cause infection to become
worse and, as a result of significant accumulation of these fluids, cause
the drowning of the affected worker.
Chronic irritation involves gradual bodily changes such as the reduction of
lung capacity. This may result in increasing one's susceptibility to upper
respiratory infections such as chronic bronchitis. In addition, since lung
capacity may be reduced and the heart has to work harder, there may be an
increased risk of cardiovascular or heart problems.
When a worker becomes sensitized (develops an allergy) to TDI, exposure may
cause a severe allergic reaction (e.g., occupational asthma). In turn, this
medical condition may cause death. Between two (2) to fifteen (15) per 100
people can become sensitized to TDI. Given a large dose, an
individual/worker can become sensitized upon the first exposure. However,
sensitization normally develops after repeated exposures. Once a worker
becomes sensitized, any level of TDI exposure can set off an allergic
reaction.
Before or soon as possible after working with TDI, affected workers should
have a complete work and medical history, lung function test, chest x-ray,
and blood tests performed. This is especially important for those workers
who have a history of upper respiratory/lung allergies, previously weakened
lungs, and lung or throat problems at the time of exposure.
Controlling the Hazard
Exposure to TDI can best be controlled by removing the substance from the
workplace. Where possible, less toxic, acceptable substitutes should be
identified and used. When isocyanate products are used, exposure can be
effectively controlled with the use of engineering controls such as enclosed
systems or methods, as well as local exhaust ventilation.
In addition, the employer has the responsibility for ensuring that CWA
members are not exposed to harmful levels of TDI. If a worker has an idea
that she/he may be exposed to harmful levels of TDI, she/he should contact
the appropriate union representative as soon as possible. If the affected
worker(s) can smell the TDI substance (a fruity smell), she/he/they should
leave the work area immediately and contact the supervisor and union
representative. In turn, until the hazard is corrected, the worker should
request alternative work.
Where TDI is used and the employer is unable to prevent CWA members from
being exposed to harmful levels (even after implementing engineering and
administrative controls), the employer must provide the workers with the
appropriate personal protective equipment. In addition to the provision of
gloves, goggles, and clothing protection, the employer must provide all
exposed workers with an appropriate respirator. Workers should use all
personal protective equipment as provided.
CWA members should practice good personal hygiene. This includes no smoking
or eating in TDI work areas. In addition, members should not wear
contaminated work clothing home. Rather, the employer should collect such
clothing and arrange for it to be cleaned.
If skin contact with TDI occurs, the affected body parts should be washed
with water for at least 15 minutes and all contaminated clothing should be
removed. Then the affected area should be treated with rubbing alcohol and
washed with soap and water. In turn, the affected worker(s) should notify
her/his/their doctor about this incident.
If TDI gets in the eyes, they should be flushed with water for at least 15
minutes. After this treatment, the affected worker(s) should contact
her/his/their physician.
If TDI is inhaled, the worker should be taken to fresh air and a doctor
should be called immediately. Oxygen can be administered by trained
personnel. If breathing has stopped, artificial respiration should be given.
OSHA Standard
The OSHA Standard sets the maximum or ceiling level of permissible TDI
exposure at 0.02 parts per million (PPM) of air. If such exposure is
exceeded, the employer must implement all necessary engineering and
administrative controls to reduce exposure to safe levels. If the OSHA
Standard is still exceeded, personal protective equipment must be provided.
In addition, as noted, NIOSH has identified TDI as a (animal) carcinogen.
Thus, the federal agency recommends that exposure to TDI be limited to the
lowest feasible concentration.
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Polychlorinated Biphenyls - PCB's & the
Workplace
Polychlorinated Biphenyls (PCBs) are toxic and persistent chemicals primarily
used as insulating fluids in electrical equipment like transformers in power
plants, industrial plants, telecommunications and utility lines, and in large
buildings across the country. PCBs have a heavy liquid, oil-like consistency.
The properties that make them commercially attractive are:
 | A high degree of chemical stability
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 | Low solubility in water
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 | Low vapor pressure
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 | Low flammability
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 | High heat capacity
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 | Low electrical conductivity and
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 | Favorable dielectric consistency.
PCBs are widely dispersed in the environment and are at low concentrations
throughout the world. This dispersion has occurred because there have been
inadequate control procedures in place to prevent hundreds of millions of pounds
of PCBs from being improperly used and disposed. This is of particular concern
because upon exposure into the environment, PCBs are not biodegradable, i.e.,
they do not break up or separate into chemical arrangements, and may result in
serious health problems among exposed humans and animals, as well as causing
significant environmental contamination/pollution.
As noted, within CWA-represented industries and sectors, PCBs have been widely
used in transformers. Most electrical transformers have been designed to operate
with the current carrying cells immersed in a dielectric fluid. PCB dielectric
fluid is known by the generic name, Askarel.
Servicing of transformers may result in exposure to PCBs. For example:
|
 | Routine servicing includes testing and filtering the fluid, replacing
gaskets, and possibly, the removal and replacement of some dielectric fluid.
Routine servicing often results in low-level exposure to workers and the
environment.
|
 | Rebuilding of PCB transformers involves draining the transformer, removing
and disassembling the core, reworking the coil or rewinding a new coil,
reassembling the core, and refilling the transformer with new fluid. Rebuilding
is necessary after a transformer has failed or after an inspection indicates
that it will soon fail.
Cleaning the inner surfaces of the transformers with solvents during the
rebuilding process, cleanup of spillage and drippings, and scrapings of
unserviceable components increases the production of PCB wastes and potential
contamination. Further, when the old coil must be disposed of separately from
the casing, the potential for workplace and environmental exposure to PCBs is
increased.
During the performance of this work, i.e., servicing transformers, it is not
uncommon for workers to be exposed to PCBs. Therefore, employers must provide
involved workers with the appropriate control procedures and personal protective
equipment to ensure that PCB exposures are eliminated/minimized.
An additional concern involves ensuring that uncontrolled PCB leaks and spills
do not occur. Such leaks/spillage could seriously contaminate both the
workplace, as well as the environment.
Health Effects
Exposure to PCBs may result in very serious health effects. Workplace exposure
occurs primarily as a result of inhalation or breathing airborne PCBs as well as
skin contact or absorption of PCBs. Short-term or acute health effects include
skin, eye, and throat irritation; breathing difficulties; nausea and vomiting;
loss of weight; and stomach pain. Long-term or chronic health effects include
cancer (PCBs are classified as a probable human carcinogen.
Controlling the Hazard
Ideally, the employer should replace PCBs with less toxic substances. However,
where this is not possible, the employer should provide all of the necessary
equipment and procedures to control worker exposures to PCBs. This would include
the development and implementation of engineering and administrative controls,
personal protective equipment and clothing, medical surveillance, personal
hygiene and sanitation procedures, and training and education programs for all
workers who work with and/or might suffer possible exposure to PCBs. Since PCBs
may cause cancer among humans, CWA members should make sure that the employer is
providing the above control equipment and procedures.
Where engineering controls do not reduce PCB exposure to levels below the OSHA
standard, respiratory protection must be provided. During this process,
employers must adhere to the OSHA Respiratory Standard, 1910.134. This rule
calls for the provision of physical examinations, fit testing, and the
appropriate cleaning and storage of respiratory equipment.
Personal protective equipment should be provided to prevent skin and eye contact
as well as to control respiratory exposure. Skin protection can usually be
achieved by wearing non-porous gloves, gauntlets, boots or shoe protection, and
aprons or heavy overalls. For major spill clean-up operations, a full suit of
non-porous clothing may be necessary. Unless the garment is heavily
contaminated, non-porous protective clothing can usually be laundered and
re-used. Work clothes should be laundered separately from other garments. Also,
eye protection such as goggles and/or face shields should be provided and worn
when there is a possibility that PCBs might be splashed into the eyes.
If PCBs are splashed or spilled on a worker, contaminated clothing should be
removed immediately and the skin washed thoroughly with soap and water for at
least 15 minutes. If PCBs should come into contact with a worker's eye(s), the
eye(s) should be cleansed for at least 15 minutes. In addition, a drop of
vegetable oil may be put into the eye(s) to relieve the irritating effect of
PCBs. Also, involved workers should notify their doctor of their exposures.
Occupational Safety and Health Administration (OSHA) and Environmental
Protection Agency (EPA) Rules
Presently, there are no comprehensive OSHA regulations concerning PCB exposure.
However, OSHA has set permissible exposure limits (PELs) for PCBs of 42%
(concentration) at 1 milligram per cubic meter (mg/m(3) and PCBs of 54%
(concentration) at 0.5 mg/m(3). (Given that PCBs are probable human carcinogens,
CWA members should consider any exposure to be excessive. Therefore, members
should ensure that employers are providing the necessary protections as
described above).
The Environmental Protection Agency (EPA) adopted a PCB Ban Rule effective July
2, 1979 that set stringent environmental exposure standards. Although EPA Rules
do not directly regulate worker exposure, the Rules do restrict or prohibit
employer PCBuse activities that, in turn, reduce the number of workers that
would be exposed.
The EPA Rule prohibits the manufacture, processing, distribution in commerce,
and "non-enclosed" uses of PCBs unless specifically authorized or exempted by
EPA. Totally enclosed uses will be allowed to continue for the life of the
equipment. Also, EPA will allow use and servicing of most existing large
electrical equipment containing PCBs under controlled conditions for the life of
the equipment. However, the manufacture of new PCB electrical equipment
(transformers and capacitors) is prohibited.
The EPA Rule also forbids the use of waste oil containing any detectable
concentration of PCBs from being used as a sealant, coating, or dust control
agent (e.g., road oiling, pipe coating, or vegetation spraying). Further,
disposal of PCBs must only take place at U.S. Government-approved disposal
sites. Any other method of disposal is illegal.
What Can You Do?
The key to making the workplace safe for all CWA workers is strong, active local
safety and health committees. The committee can identify dangerous conditions at
the workplace and discuss them with management. If the employer refuses to
resolve the safety and/or health hazard(s), the committee can request an OSHA
inspection. The committee should always coordinate its activities through the
local officers, the CWA Representatives, and negotiated safety and health
committees.
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Indoor Air Quality & the Workplace
CWA's more than 500,000 members employed in office environments are exposed
to many work-related occupational safety and health hazards. In coordination
with the Union's Occupational Safety and Health Department, local leaders and
members have identified many of these offices as containing hazardous and
unhealthful materials. A primary office safety and health problem is indoor air
pollution.
Air Quality
An indoor air pollution problem exists when a limited amount of fresh air is
circulated throughout the office (tight building syndrome), air is circulated at
too fast a rate within the workplace, toxic substances are present in the office
environment, or outside air circulated into the workplace is polluted.
There are several variables that contribute to indoor air pollution. Such
factors include the use of chemicals like formaldehyde in carpets and furniture;
carbon monoxide given off by cigarette smoke and outside traffic;
polychlorinated biphenyls contained in electrical transformers; radiation from
building insulation; ozone from copiers; and solvents used in cleaners, glues,
copiers; and the ventilation system itself.
Also, there are natural causes for indoor air pollution. For example, humans
exhale carbon dioxide, which in small quantities is not toxic, but may become
hazardous if high concentrations are allowed to accumulate. Micro-organisms or
bacteria may also be present within the ventilation system. If micro-organisms
do develop, they may spread throughout the entire workplace or building by means
of the ventilation system.
In part, air quality problems are created and compounded by the "sealed
buildings" in which many people work. The design of these buildings, intended to
reduce energy costs, is being identified as a major source or contributor to
worker-reported health symptoms.
Another reason for poor air quality may be inadequate ventilation. As noted, the
amount of fresh air and its cleanliness are important factors in determining air
quality. An efficient, well-maintained ventilation system will circulate and
substitute fresh air for used air. Although ventilation systems are not designed
to remove large amounts of air contaminants, the ventilation system may
sufficiently reduce the level of air pollution.
In the case of redesigned "open space" offices, severe ventilation problems may
exist. It is not uncommon to see partitions and walls filling previously "open
space" offices. Although such spatial divisions may provide needed privacy, CWA
members may notice that their work area contains dead or polluted air. This
situation is caused because there is inadequate circulation of fresh air. Most
often these conditions result from either not having supply and exhaust vents
within each separate room or work area or from inadequate maintenance of the
ventilation system. To ensure adequate ventilation, the employer should design
or redesign the office environment so that each work area has properly operating
supply and exhaust vents.
Health Effects
Many health symptoms that office workers experience are promoted or caused by
indoor air pollution. Physical symptoms such as headaches, sinus discomfort,
upper respiratory congestion, and eye irritation are the result of contaminated
air. Also, in some cases, indoor air pollution may cause serious infections like
Legionnaires' Disease, a type of pneumonia.
In addition, worker health symptoms such as colds, headaches, drowsiness,
irritation, and irregular breathing may be brought on as the result of
temperature extremes, improper humidity levels, and too little or too much air
circulation. Workplace temperatures should be maintained between 68 degrees - 75
degress Fahrenheit and humidity levels between 30% - 60%. In addition, drafts
caused by too much air circulation should be avoided.
Compounding the noted health symptoms may be job stress. In part, due to various
aspects of office automation, the most stressful elements of office work are
increasing. Health symptoms associated with job stress include psychological and
physical strains such as frustration, anxiety, irritability, anger, depression,
stomach or gastro-intestinal disturbances, and muscle and psychological tension.
These symptoms may be promoted by poor indoor quality.
Solving Ventilation Problems
A primary factor in the prevention of health symptoms is an efficient, properly
designed and operating ventilation system. The ventilation system determines the
quality of the indoor air by controlling the amount of air that is added to the
workplace atmosphere, the cleanliness of such outside air, and the rate at which
the office air and its pollutants are either exhausted to the outside or
re-circulated throughout the building.
Having identified office air pollution and ventilation problems, we must
consider ways of resolving them. Following are some suggestions:
First, worker health symptoms and their causes need to be identified.
Discussions with workers, review of employer-maintained records of worker
injuries and illnesses, and development, distribution, and analysis of a brief
health questionnaire should accomplish this need.
Talking with co-workers is one of the easiest ways to identify the occurrence
and, sometimes, causes of employee health symptoms. Requested information might
include the use of contaminants within the workplace, the occurrence and type of
health symptoms, and the time of the day, week, and year when health symptoms
occur most frequently.
Employer-maintained records of workplace injuries and illnesses should be
requested and reviewed. Quite often, such information will indicate the
occurrence of patterns of similar health symptoms caused or promoted by air
pollution and improper ventilation.
A health questionnaire should be developed and distributed to all concerned
workers. Such a tool should identify the number of people affected; specify ages
and job descriptions of involved workers; determine where they are located
within the office; indicate when the symptoms occur (time of day, day of week,
and time of year); provide a list of specific health symptoms or illnesses;
identify all machines operated in the workplace; indicate the type of outside
air pollution; and identify potential sources of job stress.
Second, identification of contaminant sources is often crucial to
determining the cause(s) of worker health symptoms. Such information can
sometimes be obtained by requesting copies of air monitoring data from the
employer. If monitoring data is not available, yet a high number of health
symptoms have been reported, the Union representative should request that the
employer have air monitoring tests conducted. Review of this data may identify
potentially hazardous sources of contamination and resultant worker health
symptoms. However, when contaminant concentrations are very low, monitoring data
may not explain the observed or reported health symptoms.
If no contaminant sources are found, it is still possible that an indoor air
pollution problem exists. Excessive re-circulation of air leads to "stale air"
conditions. Stale air has higher levels of carbon dioxide and carbon monoxide
(produced from human breathing and cigarette smoke, respectively) than outside
air. Stale air may also be a problem when ventilation is not sufficient to
account for an increase in the number of workers in the area.
As noted, improper temperature and humidity levels, and too little or too much
air circulation may also contribute to worker health complaints. Temperature
levels should range from 68 degrees - 75 degrees Fahrenheit and humidity levels
between 30% and 60%. In addition, drafts caused by too much air circulation
should be avoided. Maintenance of proper temperatures and humidity levels and
proper air circulation will help to reduce the occurrence of upper respiratory
symptoms, and, possibly, skin rashes.
Third, the condition of the ventilation system should be documented.
Copies of maintenance records should be requested. Analysis of this information
will indicate whether equipment is routinely serviced and operating properly.
In addition, ventilation system design operating standards, as well as minimum
fresh outside air requirements, are provided by the American Society of Heating,
Refrigerating, and Air Conditioning Engineers (ASHRAE). The ASHRAE standard
endorses the importance of worker complaints in judging indoor air quality.
ASHRAE defines acceptable air quality as:
"Air in which there is no known contaminants at harmful concentrations and with
which a substantial majority (80% or more) of the people exposed do not express
dissatisfaction."
ASHRAE calls for office environments to be provided with 20 cubic feet of fresh
outside air per minute per person (cfm/person).
Also, ASHRAE states that 1/10 the OSHA air contaminant levels should be used
when evaluating air sampling or monitoring results. This reduction is based on
the fact that OSHA standards apply to healthy workers, whereas office buildings
allow access to the general population, including the very young, the sick, and
the old. Employers should ensure that ventilation systems meet ASHRAE
guidelines.
After gathering materials to identify worker health symptoms and their causes,
this information should be organized and presented to management for resolution.
Remedies for health symptoms might include the adjustment of air handling
equipment and variation in the amount of re-circulation. Also, the rate of air
turnover can be adjusted. Ventilation ducts can be added to provide better
distribution of the air. The number of workers in an area can also be varied to
allow adherence to the ASHRAE 20 cfm/person requirements.
What Can You Do?
All CWA members should make sure that their employer is maintaining a safe and
healthful workplace, i.e., one that is free of hazardous contaminants and
supplied with clean, fresh air. The key to making the workplace safe for CWA
members is strong, active local safety and health committees. The committee can
identify dangerous conditions at the workplace and discuss them with management.
If the employer refuses to cooperate, the committee can request an OSHA
inspection. The committee should always coordinate its activities through local
officers, the CWA Representative, and negotiated safety and health committees.
In addition, CWA members may obtain information and assistance by contacting
the:
CWA Occupational Safety and Health Department
501 Third Street, N.W.
Washington, D.C. 20001-2797
Webpage: www.cwasafetyandhealth.org
Telephone: (202) 434-1160.
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Personal Protective Equipment & the
Workplace
Ideally, employers should provide employees with workplaces free of safety
and health hazards. However, due to the nature of a given work operation,
employees may be exposed to potentially hazardous chemical and physical agents.
It is not uncommon for CWA members to be exposed to such work conditions. This
is particularly true for members employed in the high hazard bargaining units
and occupations that the Union represents (e.g., manufacturing,
telecommunications service and installation, printing, and health care jobs).
As stated in the Occupational Safety and Health Act of 1970, employers must
provide workplace controls to protect employees from exposures to hazardous
substances. The type(s) of control measures that may be implemented will depend
on the nature of exposure, the substance, and its route of entry into the body:
inhalation (breathing), absorption (skin), and ingestion (swallowing).
Before making a decision on what type of control measure(s) to implement, the
circumstances surrounding the problem(s) should be thoroughly examined. For
example, in the case of an air contaminant, an exposure problem may be
minimized/eliminated by reducing the amount of the contaminant in the breathing
zone. An analysis of the source of the toxic, the path by which the contaminant
travels to the worker, and the employee's work pattern should provide the worker
with information enabling her/him to select or be provided with the most
protective control measure.
Control Measures
The best method of controlling potential occupational safety and health hazards
is through the implementation of engineering controls. Engineering controls are
design methods that prevent harmful worker exposure. Ideally, the proper time to
establish engineering controls is when the workplace is being designed. However,
quite often this is either not done or not possible. In these circumstances, the
following control measures should be considered.
Closed Systems- Where possible, work operations that involve potentially
hazardous exposures should be conducted in closed systems. Closed systems allow
for materials to be brought into the workplace in sealed containers and emptied
into storage tanks, thus preventing employee contact or exposure to the
substance. Unfortunately, not all operations lend themselves to such an
approach.
Substitution- Quite often, a less hazardous substance or process than
that currently being used may be available. Where a problem exists, CWA members
should advise the employer of this consideration. Useful examples of less
hazardous substitutes would include mineral spirits for trichloroethylene and
trichloroethane, as well as non-asbestos products to replace asbestos materials.
Changing A Process- Another control method would be altering or changing
a work operation to minimize worker exposure. For example, vapor degreasing
could be accomplished with the use of dip tanks with adequate ventilation
controls rather than having the worker hand wash parts in open containers.
Isolation- Where possible, potentially hazardous work operations might be
isolated or enclosed to reduce employee exposures. An example of this process
would be utilizing acoustic panels to reduce noise. Isolation equipment may be
operated by remote control from some protected location. The degree of isolation
should be determined by the toxicity of the substance, the amount and duration
of the contaminant exposure, and the involved work patterns.
Wet Methods- Wetting a particular substance will reduce the generation of
dust. This control method is widely utilized because it is a simple, effective,
and an inexpensive way to minimize potential health hazards. In order that this
control method works most effectively, use of a wetting agent may be required
and proper disposal procedures should be used.
Local Exhaust Ventilation- Local exhaust ventilation is a system located
at the source of contaminant generation that captures the hazardous substance(s)
before it/they escape into the workplace environment. Local exhaust ventilation
systems are a preferred control method because they remove air contaminants
rather than just dilute them. Local exhaust systems should be used when
substitution, changing the process, or enclosure are not compatible with the
work operation.
General Ventilation- General or dilution ventilation systems add or
remove air from the workplace to keep the concentration of air contaminants
below hazardous levels. General ventilation consists of the airflow through open
windows or doors, fans, and roof ventilators. It should be remembered that
general ventilation control only dilutes air contaminants unlike local exhaust
ventilation that removes air contaminants. Therefore, general ventilation should
not be used to remove great amounts of air contaminants from the workplace
environment or to control major localized sources of air contamination. When
using general ventilation systems, care should be taken not to re-circulate the
toxic substances throughout the workplace.
Personal Protective Equipment- When it is not possible or feasible to
eliminate hazardous levels of air contaminants from the workplace, it may become
necessary for the employer to provide personal protective equipment so that
toxic exposures may be minimized. However, personal protective equipment should
only be used when it is not possible to isolate a work process, provide
ventilation, or use another more protective control method. Personal protective
equipment does nothing to minimize or eliminate the source of the problem, i.e.,
the hazard. Thus, if the personal protective equipment fails to work properly,
the worker suffers immediate exposure to the toxic substance.
Personal protective devices include eye and face protection such as safety
glasses, goggles, and face shields; hearing protection like ear muffs and ear
plugs; protective clothing such as gloves, gauntlets, coveralls, aprons, and
boots; protective creams and lotions; and respirators. Importance must be placed
upon the employer furnishing the proper type of personal protective equipment
for specific work operations and exposures. For example, when an employee is
working with a particular solvent, she/he should be provided the proper gloves
to prevent the substance from seeping through the glove and causing harmful skin
contact.
More and more, employers have begun emphasizing the use of respirators rather
than implementing adequate engineering controls. Respirators should not be
viewed as a substitute for engineering controls. Rather, when used, they should
be seen as offering only short-term or emergency protection. An approved
respirator should be appropriate for the particular hazard or work environment
in which the respirator is to be utilized (e.g., dust masks should not be used
to protect against chemical exposures). In addition, the type of air
contaminant, it's expected maximum concentration, the possibility of oxygen
deficiency, the life of the respirator, and available escape routes should be
determined before the work is initiated. Before supplying employees with
respirators, employers should give them complete physical examinations to
determine workers' adaptability to respirators and provide them thorough
respirator protection training programs.
Personal Hygiene- Employers should make hand-washing facilities readily
available to employees working with or near toxic substances. It is important
that workers be able to wash promptly in case of accidental splashes of toxic
substances. Also, where called for, convenient access to emergency showers
should be provided. Eating and storage or drinking of foods and liquids should
be forbidden where toxic substances are used.
Regulated areas, where biological hazards or proven or suspected cancer-causing
agents are used or handled, should be properly marked to inform workers of the
potential hazards and the regular and emergency procedures required. Employers
should also provide workers who enter such areas with a place to change
protective clothing and equipment.
Medical Controls- Medical controls should be an extremely important part
of an employer's safety and health or medical program. Such controls would
include a physical examination for all workers, consisting of a thorough medical
and work history including exposures to toxic and hazardous substances.
Audiometric tests should be a part of the physical examination. Results from
these exams provide baseline data that, with the results of periodic exams,
allow for the detection of the harmful effects of particular work operations and
the evaluation of their severity. Medical records must be maintained by the
employer and made available to requesting employees.
In addition to periodic medical examinations, workplace exposure monitoring
tests should be conducted on a periodic, regular basis. Instrumentation that
continuously monitors the work environment for airborne contaminants and
triggers an alarm when concentrations exceed safe levels should be obtained and
used. Use of information from both physical examinations and workplace exposure
monitoring can be an effective method of discovering potential occupational
safety and health hazards.
Administrative Controls- An employer might decide to use administrative
controls to minimize occupational exposure to toxic substances. One type of
administrative control would be a reduction of work periods for jobs that
involve exposure to toxics. For example, by transferring an employee who has
worked four hours at an operation involving exposure to hazardous
substances/agents to work at a less hazardous task for four hours, the worker's
toxic exposure is minimized. Administrative controls should not be viewed as
long-term substitutes for engineering controls, and other more effective methods
of minimizing exposures to hazardous substances.
Maintenance- All employers should make sure that adequate maintenance
schedules are established and adhered to. Poor maintenance of workplace
equipment usually causes poor operation of machinery and, in turn, increased
workplace accidents and illnesses. A regular maintenance schedule should include
periodic shutdowns of all equipment. In addition, employees performing
maintenance should be provided with the necessary personal protective equipment.
Good Housekeeping- It makes sense for companies to establish and maintain
good housekeeping practices. Proper good housekeeping procedures include a
thorough cleaning of the workplace, as well as adequate washing, toilet, eating,
and waste disposal facilities. Employers should ensure that toxic substance
spills are cleaned immediately. Work practices should also be in effect for the
safe disposal of toxic chemicals and other hazardous substances.
Training- All employers representing CWA members should have effective
training programs that deal with employees' working conditions. Part of this
training should include information on the types of occupational hazards,
adequate coverage of personal protective equipment, a medical surveillance
program, and emergency situations. Where companies have not formulated such a
training program, CWA-represented workers should encourage them to do so.
What Can You Do?
All CWA members should make sure that their employer is maintaining a safe and
healthful workplace. The key to making the workplace safe for all CWA members is
strong, active local safety and health committees. The committee can identify
dangerous conditions at the workplace and discuss them with management. If the
employer refuses to cooperate, the committee can request an OSHA inspection. The
committee should always coordinate its activities through the local officers,
the CWA Representatives, and negotiated safety and health committees.
In addition, CWA members may obtain information and assistance by contacting
the:
CWA Occupational Safety and Health Department
501 Third Street, NW
Washington, D.C. 20001-2797
Webpage: www.cwasafetyandhealth.org
Phone: (202) 434-1160.
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Freon is a generally colorless, non-flammable gas or liquid. It is primarily
used as refrigerant and polymer intermediates. Freon is also used in the
degreasing of electrical equipment, in aerosol propellants, anesthetics, fire
extinguishers, foam blowing agents, and in dry cleaning. Freon is used because
of its low toxicity to humans. However, freon is a significant environmental
toxin.
Health Effects
Freon is an irritant to the eyes and respiratory passages. Contact with skin may
cause dermatitis of skin rashes. Exposure to high concentrations of the chemical
can cause dizziness and lack of coordination. Asphyxiation may even be the
result of freon exposure.
Freon is taken into the body by inhalation of vapor or gas.
Medical Surveillance
There are no specific diagnostic tests for the toxic effects which occur at high
concentrations of freon exposure. Employers should provide all employees who
work with or around freon with annual physical exams. (If the employer does not
presently give such exams, these should be negotiated into the collective
bargaining agreement.) All physical exams should consider possible cardiac or
heart effects from acute exposure.
Personal Protective Equipment
Employers should provide exposed workers with the following personal protective
equipment:
- non-porous gloves, aprons, and goggles; and
- the workplace should also be well-ventilated.
What Can You Do?
The key to making the workplace safe for all CWA members is strong, active Local
safety and health committees. The committee can identify dangerous conditions at
the workplace and discuss them with management. If the company refuses to
cooperate, the committee can request an OSHA inspection. The committee should
always coordinate its activities through the Local officers, the CWA
Representatives, and negotiated safety and health committees.
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Vinyl Chloride & the
Workplace
Vinyl chloride is a flammable gas at room temperature and is usually
encountered as a cooled liquid. The colorless liquid forms a vapor which has a
pleasant odor. Vinyl chloride is used as a vinyl monomer in the manufacture of
polyvinyl chloride and other resins. It is also used as a chemical intermediate
and as a solvent.
The danger comes during the production process. Three basic steps are necessary
to the production of vinyl products. First, the vinyl chloride, or monomer, is
produced in a closed process. The vinyl chloride monomer is then shipped as a
compressed liquified gas to plants that produce the polyvinyl chloride resin.
Batches of vinyl chloride are polymerized by mixing them with catalysts in giant
vats or reactors. After drying, the polyvinyl chloride resins are compounded by
the addition of stabilizers, lubricants, and plasticizers. The fabrication end
of the polyvinyl chloride industry covers a huge range of processes in which the
polyvinyl chloride is turned into a myriad of finished products.
Health Effects
Vinyl chloride gas is absorbed by inhalation. Skin absorption may also be
another route of entry. Vinyl chloride is a skin irritant causing a skin rash or
contact dermatitis. Contact with the liquid may also cause frostbite upon
evaporation. Contact with the eyes will produce immediate and severe irritation.
Vinyl chloride depresses the central nervous system causing symptoms which
resemble mild alcohol intoxication. Lightheadedness, nausea, and dulling of
visual and auditory (hearing) responses may develop in acute exposures. Severe
vinyl chloride exposure has resulted in worker death.
Chronic or long-term exposure may result in skin changes and liver damage. Vinyl
chloride is considered a human carcinogen. specifically, the chemical has caused
cancers of the brain, liver, and lungs which normally cannot be diagnosed until
the disease is incurable. In addition, workers may not show any symptoms until
at least fifteen years after the initiation of exposure.
Medical Tests
Presently, there are no special medical tests to diagnose the hazardous
consequences of vinyl chloride exposure. However, CWA members who work with
vinyl chloride must be provided with employer paid periodic physical
examinations. Such exams should emphasize liver function and palpation. Liver
scans have been successful in detecting liver tumors. Medical histories should
include alcohol consumption, past liver ailments or infections, exposure to
agents which may be harmful to the liver, drugs and chemicals, past blood
transfusions, and past hospitalizations. Long-term medical follow- up for
workers exposed to vinyl chloride is a must.
When a CWA member who works with vinyl chloride suffers bad health, he/she
should consult a physician as soon as possible. The worker should mention to the
doctor that he/she works with vinyl chloride.
In cases of acute poisoning due to vinyl chloride, the victim should be taken
into fresh air or a well-ventilated room. Clothes contaminated by vinyl chloride
should be taken off and removed from the area. If the worker stops breathing,
artificial respiration should be given. A doctor should be called immediately.
Controlling the Hazard
The best workplace control to vinyl chloride exposure is substitution of a less
hazardous and harmful material. Although less protective enclosure of the
process might also be considered. Where this is not possible, CWA members should
utilize employer provided personal protective equipment such as non-porous
gloves, goggles, non-porous aprons, sleeves, boots, and, where vinyl chloride
levels cannot meet the OSHA Standard, respiratory protection.
The OSHA Standard
The OSHA Standard applies to the manufacture, reaction, packaging, repackaging,
storage, handling, or use of vinyl chloride or polyvinyl chloride in such
operations as molding, extrusion, mixing, and calendering. The Standard does not
apply to the handling or use of fabricated products made of polyvinyl chloride
such as thermoforming or blister packaging.
The Standard sets the following permissible exposure limits:
- No worker may be exposed to vinyl chloride at concentrations greater than
one part per million (ppm) average over any eight hour period.
- No worker may be exposed to vinyl chloride at concentrations greater than
five ppm (action level) over any period not exceeding fifteen minutes.
- No worker may be exposed to vinyl chloride by direct contact with liquid
vinyl chloride.
In addition, the Standard mandates the employer to initiate a monitoring
program, to eliminate hazardous exposure to vinyl chloride through engineering
controls, to supply respiratory protection where necessary, to institute a
comprehensive training program related to the hazards of vinyl chloride and
precautions for its safe use, to initiate a medical surveillance program for all
exposed CWA members, to post legible signs where vinyl chloride is used and to
legibly label vinyl chloride containers, and to begin recordkeeping and
reporting procedures relative to worker exposure to vinyl chloride.
What Can You Do?
All CWA members should make sure that their employer is maintaining a safe and
healthful workplace. The key to making the workplace safe for all CWA members is
strong, active Local safety and health committees. The committee can identify
dangerous conditions at the workplace and discuss them with management. If the
company refuses to cooperate, the committee can request an OSHA inspection. The
committee should always coordinate its activities through the Local officers,
the CWA Representatives, and negotiated safety and health committees.
Back to top
Occupational Stress & the
Workplace
The Physiology of Stress
Occupational stress is one of the major health hazards of the modern workplace
(in which CWA members are employed). It accounts for much of the physical
illness, substance abuse, and family problems experienced by millions of blue
and white collar workers. Also, occupational stress and stressful working
conditions has been linked to low productivity, absenteeism, and increased rates
of accidents on and off the job.
Work is a central part of human life. It is the expression of the basic need to
accomplish, to create, to feel satisfaction, and to feel meaningful. Rewarding
work is an important and positive part of our lives. However, when work denies
people an opportunity to utilize their creativity, intelligence, and
decision-making ability, it causes stress.
The traditional response of management has been to "blame the victim," defining
stress as an individual or "personal" problem that workers bring from home to
work. In contrast to this approach which blames people for their inability to
fit into an inhumane work environment, it is important to analyze the structure
of job requirements and social relationships at work as the primary sources of
stress.
With the introduction of new technologies, many jobs have become more fragmented
and job tasks have been narrowed, leaving workers more disconnected from the
final product. This process of "deskilling" has created increased levels of
boredom, making work less challenging and less satisfying for many workers.
Offices are becoming factories with rows of workers connected to computers that
are capable of monitoring every key punched. The knowledge that every minute of
one's working day is being recorded has intensified the pressure of the job,
which, in turn, has led to an increased rate of heart disease among office and
clerical workers.
Although office work has always been stressful, recent scientific studies and
surveys have helped focus attention on the issue of job stress. The Framingham
Heart Study, completed in February, 1980, found that female clerical and
secretarial workers developed coronary heart disease at twice the rate of other
workers. The National Institute for Occupational Safety and Health (NIOSH) found
that operators of computers experienced greater job stress than any other
occupational group that NIOSH had ever studied. The CWA/North Carolina
Occupational Safety and Health Project Office Workers Stress (computer) Survey
found that computer use and job stress may result in the occurrence of chest
pain among CWA members who use computers.
Further, the landmark CWA National Occupational Stress Study (1990) found that
one stressor, electronic performance monitoring, was a major cause/promoter of
physical and psychological health complaints. Monitored workers reported more
boredom, high tension, extreme anxiety and depression, anger, and severe fatigue
than non-monitored workers. Also, monitored workers reported more
musculoskeletal problems (i.e., wrist, arm, shoulder, neck and back problems)
and headaches than non-monitored workers.
In 1992, NIOSH reported the findings of a scientific study regarding computer
use and associated musculoskeletal health effects involving CWA and US West.
This investigation identified several factors such as fear of being replaced by
computers, increasing work pressure, lack of job diversity with little decision
making opportunity, high information processing demands, and surges in workload
as being related to computer musculoskeletal repetitive motion illnesses.
In addition to the above variables, uncertainty about one's future (occupation),
lack of co-worker and supervisor support were found to be associated with the
cause of computer work environment musculoskeletal repetitive motion health
symptoms.
During 1998, CWA's Occupational Safety and Health Department and the School of
Public Health, Johns Hopkins University completed a major computer study
involving Union leaders and members of Locals 2101 and 2150 located in
Baltimore, Maryland. The nearly 250 participating members were employed as
service representatives by Bell Atlantic and American Telephone and Telegraph
(AT&T). The scientific investigation, initiated in 1996, addressed the
relationship among occupational stress, stress at home, and health symptoms of
musculoskeletal disorders or repetitive motion illnesses.
The findings from the study indicated that computer workplace repetitive motion
health symptoms involving the hands, elbows, shoulders, neck, back, and legs
occurred among a large number of participants. In addition, the scientific data
found that job demand occupational stressors (e.g., constant and fast pace of
the job, sales and adherence requirements, and scheduling) were directly related
to the occurrence of computer workplace musculoskeletal disorder symptoms. Of
particular importance, the investigation did not find any relationship between
non-occupational stressors (e.g., stress at home) and the causation of
repetitive motion health symptoms.
Occupational or job stress may be defined as a "mechanism whereby the human body
attempts to adapt to the environment." The body has a normal mechanism for
dealing with stressful situations which is known as the "fight or flight"
response. As soon as the brain senses danger, it sends messages (electrical,
chemical, hormonal) which stimulate the extra energy needed to fight the danger
or run away from it. The stress cycle always includes the danger stimulus, the
removal of the danger, and a state of relaxation.
The "fight or flight" response is extremely functional when we confront
short-term specific dangers. When the danger or challenge is removed or has been
dealt with, the body returns to a state of equilibrium.
Many of the sources of stress at work have a different character--they are more
subtle, more pervasive, and come from a variety of factors. Whether it's
increased workload, eyestrain from staring into computers, unpredictable
disciplinary action by a supervisor, or never being complimented about the
quality of work we produce, these all cause the "fight or flight" response to be
triggered. Since we have "gotten used to" working in stressful environments,
however, we may be unaware of the body's reaction. Yet even if we are not
conscious of it, the demands of being in a constant "on-alert" state takes its
toll on our physical health and emotional well-being.
When the cause of the stress can be identified, is of short duration, and can be
responded to by a specific set of actions which eliminate the cause, this is a
healthy stress reaction. However, when the source of the stress is not
identifiable, becomes excessive, repeated, prolonged, or continuous, it becomes
"dis- stress" and creates unhealthy physiological and psychological reactions.
To understand why exposure to stress, especially prolonged stress, can cause ill
health, it is helpful to know what changes take place in the body during the
"fight or flight" response. The heart starts beating faster in order to get more
blood to the muscles, adrenaline and other hormones are released to provide more
energy, additional stomach acids are secreted, and respiration increases. All
these changes are intended to prepare the body for action. When these bodily
processes are constantly functioning, however, our bodies are working overtime.
Under these circumstances, the entire system is weakened and the weakest spots
are the first to show signs of strain. If this burden continues over long
periods of time without adequate chances for relaxation, the entire body may
start to break down.
Job control determines how much or how little control a worker has over his/her
job. It can be defined in terms of one's ability to make decisions about how
work is done and the ability to use a range of skills on the job.
Job demand determines how much or how little production or productivity
pressures there are on the worker and the quality of the physical work
environment.
Examples of job control stressors include:
 | lack of control over your work;
|
 | lack of recognition for work done;
|
 | job insecurity;
|
 | fear of layoffs;
|
 | harassment;
|
 | lack of respect from supervisors;
|
 | racism;
|
 | age discrimination;
|
 | inadequate pay;
|
 | isolation from fellow employees either physically or psychologically; and
|
 | lack of promotion opportunities. |
Examples of job demand stressors include:
 | contracting out work;
|
 | fragmentation/job declassification;
|
 | poor ventilation and heating;
|
 | poor lighting;
|
 | forced overtime;
|
 | shiftwork;
|
 | speed-ups;
|
 | conflicting job demands;
|
 | physical danger;
|
 | fear of accident or even death on the job;
|
 | poor computer workstation;
|
 | monitoring (e.g., AWT standards);
|
 | lack of training; and
|
 | unnecessary paperwork. |
The Psychology of Stress
For most people work is the central part of their lives. It's the place where
they spend most of their waking hours and most of their energy. Moreover, how we
judge ourselves and measure our self-worth is very much determined by the work
we do. The status and rewards that society attaches to jobs is one of the
primary ways others see us. Therefore, if work is unfulfilling in that it
prevents workers from fully realizing their own potential and developing their
human capacities, the nature of work becomes a primary stressor in our lives.
Under these conditions, we experience an important aspect of our daily lives as
an assault on our dignity as human beings.
The myth that our social and economic system is based on rewarding merit often
results in people blaming themselves and co-workers for problems they encounter
in dealing with stressful working conditions. In turn, management uses this
"blame the worker" attitude to control and divide workers upon racial, ethnic,
sex, age, religious, and occupational differences.
Keeping workers divided, distrustful, and believing they are different from one
another helps frustrate attempts by workers to challenge existing working
conditions. Many of these strategies are devised by management consulting firms
and then implemented in the workplace. Union-busting courses are now a
multi-million dollar yearly enterprise. So keeping workers divided has become
big business and it is up to workers and their unions to make sure that the
natural alliances within the workforce are maintained and strengthened.
Besides the existing divisions which have been identified as some of those often
used by management to keep workers divided, the belief that "you get what you
deserve" also keeps us from relating to co-workers. How does this happen? When
we are feeling inadequate, upset, insecure, or threatened, we often hesitate to
talk about it, due to the belief that we are the only ones experiencing these
problems. In so doing, we keep ourselves from connecting with co-workers and the
Union and end up feeling isolated. Learning to appreciate co-workers as allies
is the first step in overcoming the divisions and isolation. Moreover, it is
only through the Union that workers can effectively implement common strategies
to challenge stressful working conditions.
Among the major negative effects of job stress are its impact on a person's
self-image and self-esteem, which in turn, affects their relationship with
family, friends, and co-workers. The problems last far longer than the time we
spend at work and are not easily left behind at the end of the day. So analyzing
working conditions as a primary source of stress is an important first step in
overcoming it, especially because in many situations the long-term effects show
up in our private lives and the workpla |