Federal government regulation of occupational skin exposure in the USA.

Abstract

There are at least 14 federal regulations and three agencies that are involved in the regulation of occupational skin exposures in the USA. The Environmental Protection Agency (EPA) requires the reporting of health effects information on chemicals, and such information is used to assess the risks of human and environmental exposure. The health effects information and any resulting risk assessments are generally available to the public. A fair amount of this information relates to skin irritation, sensitization, and dermal absorption. The EPA can require the submission of new data necessary for it to carry out its risk assessments, and has the authority to ban hazardous chemicals for certain uses. The Food and Drug Administration (FDA) regulates the correct labeling of cosmetics and requires safety and efficacy data on new products that are claimed to have preventive or health benefits. Commercial distribution of topical skin-care and protection products, therefore, can be potentially scrutinized by the FDA, which can control the use of hazardous chemicals in such products. The Occupational Safety and Health Administration (OSHA) has the most direct contact with workplaces through its field inspection compliance activity, which is directed at the reduction of workplace injuries and illnesses. Our analysis suggests that although considerable amounts of health effects information is generated and available, such information may not always be adequately conveyed to the end users of chemical products. In addition, the most effective and practical means of preventing exposure is often not apparent or generally known. Current regulations may have created a reliance on use of chemical protective equipment that may not always be the best approach to protecting workers. Lack of performance criteria that are measurable has hampered industry from objectively assessing skin exposures. This lack of performance criteria or guidance has also hindered the implementation of prevention strategies and a critical assessment of their effectiveness. Better guidance from regulatory agencies directed at performance-based control of occupational skin hazards is presently needed.