NIOSH Responds to CRE Data Quality Letter
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Jim J. Tozzi
Dear Mr. Tozzi:
Thank you for your letter of March 9, 2001 concerning the National Institute for Occupational Safety and Health (NIOSH) Hazard ID Number 10: Workers Exposed to Class B Biosolids During and After Field Application. We hope to clarify for you the process NIOSH used for the development of this document and to address other issues you raised.
NIOSH is the federal agency charged with conducting research into occupational safety and health issues and disseminating the results of that research to employers and employees (Occupational Safety and Health Act, 29
U. S. C. § 651 to 678). The Hazard ID is a type of brief document that NIOSH issues to provide employers, workers, and others in the public with timely information on the results of NIOSH studies at a specific worksite, to identify new or current hazards, and to provide recommendations on ways to protect the health or safety of workers. This specific Hazard ID for biosolids workers was generated in response to a NIOSH evaluation that found a combination of worker exposure to enteric bacteria from Class B biosolids at a land application operation and gastrointestinal illness among the exposed workers.
The Hazard ID describes the health hazards of Class B biosolids based on current medical and scientific understanding and acknowledges scientific limitations in the available information. It documents airborne exposure to fecal bacteria following typical work practices that disturb biosolids, and it provides a variety of basic safety and health recommendations that can be taken to protect workers from potential exposure to class B biosolids, consistent with standard public health practice. It also includes an explicit statement that the recommendations are not intended to address non-occupational exposure.
NIOSH consulted with the Environmental Protection Agency (EPA) in developing this document, and continues to coordinate with EPA regarding both agencies' efforts to disseminate information related to biosolids. Consistent with its normal practice, NIOSH submitted this Hazard ID to external scientific peer review before its finalization and public release. NIOSH selected peer reviewers from the National Center for Infectious Diseases, EPA, and an international corporation which provides waste management services to a large number of governmental and private organizations. NIOSH addressed the comments made by these external reviewers before finalizing the document.
You have raised questions concerning whether NIOSH complied with the Office of Management and Budget (OMB) Circular No A-130, which provides federal information management policies as required by the Paperwork Reduction Act of 1980 (PPA), as amended by the PPA of 1995, in releasing this Hazard ID. We have carefully reviewed your letter and the OMB Circular and believe that NIOSH was fully compliant with the Circular in releasing the Hazard ID.
Finally, you raised questions regarding the Institute's failure to respond to a letter sent by the Association of Metropolitan Sewerage Agencies (AMSA) and Water Environment Federation (WEF) concerning this Hazard ID. NIOSH did respond to this letter in December, 2000 but apparently our response was not received by AMSA and WEF. Upon learning this, we forwarded our response to them again, and we enclose a copy here. NIOSH is ready to meet with representatives from both organizations to discuss any remaining concerns they may have and to work with them on possible partnership activities.
cc: James Seligman/CDC