My colleagues and I in the Occupational Health and Safety Specialty Group of the Society for Risk Analysis organized a symposium for the SRA 2017 Annual Conference in Arlington, VA, last week. Here is a brief overview of what we talked about.
Specifically, the symposium was about a policy of “continuous quality improvement” to occupational and environmental health management. The idea is to take a Deming-like approach similar to quality management in the private sector, rather than setting fixed regulations, especially exposure standards, that are evidence-based reflecting knowledge at the time but inevitably have to be revised later based on new information and experience.
Current approaches to regulatory risk management based on standard-setting assume that the standard represents a permanent best practice and a level of risk that is appropriate for the level of protection required by the community at risk. However, new information, improved scientific methodology, and the identification of novel risks often require review and modification of standards for significant hazards. As well, social attitudes change and society generally becomes more risk-averse over time and with increasing awareness and affluence.
An alternative approach that recognizes these realities is “continuous quality improvement” (CQI), which is an on-going process for the optimization of risk, efficiency of operations, and consumption of resources. The “Deming Cycle” (Plan® Do® Study® Act® [repeat]), for example, is the standard management approach for quality assurance in the private sector.
CQI has theoretical and practical advantages over fixed standard setting in improving the quality of the environment and worker health and fits better with good management practices. The theoretical disadvantages may be business concern over an ever shifting target for compliance and the opportunity cost of making improvements when performance is already sufficient. However, in practice, CQI has shown such great benefit in improving the operations of enterprises from small business to large corporations that it is standard procedure and typically results in large unanticipated gains beyond quality, in efficient operations, lower cost, and reduced risk.
Examples of situations in which we already use CQI include ACGIH TLV’s and BEIs and other examples of public policymaking by private organizations, the International Organization for Standardization (ISO), the WHO process for Basic Occupational Health Services, The mandated periodic review (Integrated Review Plan) of ambient air quality standards by the EPA, the internal regulatory framework of high-value globalized Pharma (an industry where chemicals are supposed to be biologically active), the UK HSE’s doctrine of “as low as reasonably practicable”, and management of high-priority chemicals under the Lautenberg Chemical Safety Act are broadly compatible with CQI. The CQI approach is also one means of effectively operationalizing the Precautionary Principle.
CQI has its attractions as a concept because it is technology- and opportunity-driven, produces side benefits, sidesteps costly litigation about standards (potentially) and is robust (meaning that it is not dependent on the latest research findings or interpretation.
There are, of course, drawbacks to CQI. The big objection would be opportunity cost. Opportunity cost provides an excuse, or “cover” for externalities, however. Injury risk and non-obvious harm to workers can be marginalized with the argument that resources could expand production and be invested in new technology or facilities that would make the workplace even safer. I have yet to see a convincing example of this tradeoff. Rather, it seems to me that the demand for incremental improvement over time removes much of the arbitrary compromise in standards-setting and over time may lead to greater gains than lurching from one standard to another with a political battle at each step.
A second objection would be feasibility of management. Evaluation would be as difficult as it is now and there would be constant pressure to halt improvement on the grounds that “safe enough is enough”.
A third objection would be that the proposal is counter-precautionary, in that on the way to incremental improvement the approach allows some measure of pollution on grounds of benefit and technological feasibility. This is actually not much different than under current standards.
A fourth objection could be that this approach creates a shifting playing field for business. One could argue, however, that knowing that a standard requires reduction of risk over time and adoption of best practices on an on-going basis is actually a more level playing field than fighting sequential battles for revision of conventional standards.
In this construct, CQI would not only drive permissible exposure lower as technology improves, but would almost certainly have secondary gains in efficiency, which is the experience in industry. CQI has roots in the way business approaches quality management and increased efficiency. CQI should be considered as an alternative regulatory approach at all levels of regulation: national, enterprise, and workplace. It should be recognized as a fundamental approach to risk management.
The rest of the symposium looked like this:
Society for Risk Analysis Annual Meeting, 10 December 2017. Sponsor: Occupational Health & Safety Specialty Group. Cosponsors: Economic Benefits Analysis Specialty Group, Risk Policy & Law Specialty Group.
Symposium M2-D: Continuous Quality Improvement: An Alternative to Standards Setting?
Chair: Tee Guidotti, Chair of the Occupational Health and Safety Specialty Group
10:30 AM M2-D.1 Continuous Quality Improvement (PDCA) in Risk Management: The Deming Cycle in Achieving Risk Reduction Beyond Fixed Standards. Guidotti TL, Occupational + Environmental Health & Medicine
10:50 AM M2-D.2 Manufacturing Novelty for a Purpose: the Neuroscience Basis for Continual Review and Improvement. Mary V. O’Reilly MV, ARLS Consultants, State University of New York
11:10 AM M2-D.3 Manifesting Quality Management and CQI in Environmental, Health and Safety: ISO’s Approach. Charles F. Redinger, The Institute for Advanced Risk Management
11:30 AM M2-D.4 Practical Considerations for Recycling Mercury-Impacted Scrap Metal (Case Study). Molly Finster and MacDonell M, Chang YS, Argonne National Laboratory
11:50 AM M2-D.5 Discussion. Deborah Aiken, representing the SRA Economic Benefits Analysis Specialty Group (cosponsor of the symposium).
© Tee L. Guidotti, 2017.