Implementation Plan

Attachment D: HHE local health department survey, Implementation Plan

NIOSH
Health
Hazard
Evaluation
Program
Plan to Implement
the National
Academies Program
Evaluation
Recommendations
April 2010

Attachment D: HHE local health department survey, Implementation Plan

Executive Summary
The National Institute for Occupational Safety and Health (NIOSH) Health Hazard
Evaluation (HHE) Program underwent a systematic review for relevance and impact by
the National Academies (NA) beginning in 2007. The NA concluded in their 2008 report
that the NIOSH HHE Program was highly effective in investigating and advising
workplaces, fills a special need in the occupational health community, and has a major
impact on improving occupational health. The NA gave the HHE Program a score of 4
for relevance and a score of 4 for impact. The NA identified several areas in which the
HHE Program could be strengthened. It offered the following eight overarching
recommendations, and more specific recommendations for items 2-8.
Recommendation 1: Conduct regular assessments of performance measures to determine
whether available resources allow more ambitious goals.
Recommendation 2: Improve the mechanisms by which requests for HHEs are sought and
prioritized to include a broader array of requests from a wider variety of requestors.
Recommendation 3: Ensure that recommendations in HHEs are relevant, feasible,
effective, and clearly explained.
Recommendation 4: Use the HHE Program to develop occupational health professional
resources.
Recommendation 5: Develop a proactive, comprehensive information-transfer strategy
for HHE Program outputs with better approaches to reaching wider audiences, including
traditionally underserved populations.
Recommendation 6: Develop more extensive formal linkages and mechanisms with other
parts of NIOSH, CDC, and HHS to enhance the capacity for involvement in policyrelevant impacts.
Recommendation 7: Initiate formal periodic assessment of new and emerging hazards.
Recommendation 8: Continue to provide guidance and recommendations during public
health emergencies.
This implementation plan describes current and planned efforts to respond to these
recommendations. The NIOSH HHE Program reports progress to date on some of the
recommendations. Over the next 3-5 years, primary emphasis will be given to increasing
awareness of the HHE program to ensure that 1) its services are available to meet the
changing needs of the American workforce and 2) the information learned from its
investigations reaches all those who have a role in ensuring safe and healthy workplaces.

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Table of Contents
Executive Summary ............................................................................................................ ii
1
Introduction to the Health Hazard Evaluation (HHE) Program ................... 1
1.1
Mission ......................................................................................................... 1
1.2
Goals ............................................................................................................. 1
2
Background on National Academies Review ............................................... 2
3
Implementation Plan..................................................................................... 3
3.1
Purpose ......................................................................................................... 3
3.2
Development Process ................................................................................... 3
3.3
External Factors ............................................................................................ 4
3.4
Vision ........................................................................................................... 4
4
HHE Program Response to the NA Recommendations ............................... 4
Overview ...................................................................................................... 4
4.1
4.2
Inputs ............................................................................................................ 5
4.2.1
Improving the triage of HHE requests .......................................................... 5
4.2.2
Expanding the base from which HHE requests are received ........................ 6
4.2.3
Increasing opportunities to recognize emerging issues ................................ 9
Preserving program resources during emergencies .................................... 10
4.2.4
4.3
Outputs ....................................................................................................... 11
4.3.1
Enhancing the quality and helpfulness of HHE reports .............................. 11
4.3.2
Expanding opportunities to train occupational health professionals .......... 13
4.4
Transfers ..................................................................................................... 14
Improving dissemination channels and developing partnerships to enhance
4.4.1
dissemination .............................................................................................. 14
4.5
Intermediate Outcomes............................................................................... 16
4.5.1
Establishing partnerships with government programs that can use HHEgenerated information................................................................................. 16
Program Evaluation .................................................................................... 17
4.6
4.6.1
Evaluating various aspects of the program formally and regularly ............ 17
Table 1. Strategic and Intermediate Goals of the HHE Program .................................. 19
Table 2. Overview of Recommendations...................................................................... 20
Figure 1. Health Hazard Evaluation Program Logic Model ......................................... 27
Appendix A – Revised Criteria for Field Investigations ................................................ 1

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1 Introduction to the Health Hazard Evaluation (HHE)
Program
1.1 Mission
The National Institute for Occupational Safety and Health (NIOSH) is the federal agency
responsible for conducting research and making recommendations to prevent
occupational illness and injury. NIOSH is part of the Centers for Disease Control and
Prevention (CDC) in the Department of Health and Human Services (DHHS). The Health
Hazard Evaluation (HHE) Program carries out the NIOSH mandate to respond to requests
for investigations to learn whether exposures or conditions in specific workplaces pose a
health hazard to workers. These investigations are termed health hazard evaluations, or
HHEs. We use the term HHE to refer to our response including field investigations and
office-based technical assistance.
The HHE Program has a unique role in NIOSH as an external sensor for current and
emerging issues, helping the Institute stay relevant with regard to occupational health
issues in today’s workplaces. The HHE Program can be likened to a hospital emergency
department, reflecting events happening in the community and serving as one of the first
places people go for assistance in solving workplace problems. The HHE Program was
designed to deal with problems whose causes, implications, and solutions are not well
understood.
The HHE Program contributes to the NIOSH mission through a diverse set of activities
and outputs. The Program’s mission is to protect worker health through problem solving,
research, risk communication, and dissemination of findings and recommendations by
responding to external requests for hazard evaluations and technical assistance.

1.2 Goals
We formalized a strategic plan in response to a recommendation by the NIOSH Board of
Scientific Counselors (BSC) in 2006. The National Academies (NA) review committee
noted that the “goals are well targeted and relevant, and can be measured by the number
and types of HHE requests received, the number of reports and field investigations
conducted related to each of these goals, and their effects as determined through
followback surveys.” The NA committee further stated that “Appropriate performance
measures for each intermediate goal have been chosen, given the limited resources of the
program.” Because of the emphasis given by the NA to the occupational health
professional training role of the HHE Program, we added a new Strategic Goal
addressing this issue. We believe that the strategic and intermediate goals enumerated in
Table 1 (Page 19) will serve the program well over the next 5 years. The wording of
some goals has been revised from earlier versions of the strategic plan to follow current
NIOSH guidance for programs in the NIOSH Program Portfolio. That is, strategic goals
describe a specific desired change in the social system, intermediate goals describe the
desired activities that organizations or individuals undertake with the outputs created by

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the program, and activity/output goals are statements of desired program activities,
including outputs and transfers to stakeholders. Performance measures are metrics
indicating progress toward the goals.

2 Background on National Academies Review
As part of a series of planned reviews of NIOSH research programs, NIOSH contracted
with the NA to evaluate the HHE Program. In requesting this review, NIOSH and the NA
recognized that the HHE Program, unlike most other programs evaluated by the NA for
NIOSH, is not a traditional research program but a program whose primary focus is to
carry out public health practice activities in response to requests for assistance. The NA
convened a committee of experts to evaluate the relevance of the HHE Program’s work in
improving occupational safety and health and the impact of its work in reducing
workplace injuries and illnesses. NIOSH asked the NA to assign two numerical scores for
its assessment, one for relevance and one for impact. NIOSH also asked the NA to
examine future issues and provide recommendations for its vision for the HHE Program.
We prepared an evidence package documenting the activities, outputs, and outcomes of
the HHE Program, focusing on the most recent 10 years. Print and electronic copies of
the evidence package were given to the NA. The electronic version can be found at
http://www.cdc.gov/niosh/nas/hhe/. The print version is available upon request from the
HHE Program (http://www.cdc.gov/niosh/programs/hhe/contacts.html).
After completing its review, the NA Evaluation Committee presented its findings to
NIOSH and subsequently published the report titled The Health Hazard Evaluation
Program at NIOSH.
The NA assigned the HHE Program a score of 4 (out of 5) for both relevance and impact.
The report noted that “If the committee had not been restricted to the use of integers, both
scores would have been between 4 and 5.” The NA found that the HHE Program is
“highly effective in investigating and advising workplaces when requested. The program
fills a special need in the occupational health community by investigating unexpected or
underestimated workplace hazards and relating them to worker exposures or
circumstances.” Overall, the committee considered the HHE Program to be “highly
relevant and to have a major impact on improving occupational health.”
The NA identified several areas in which the HHE Program could be strengthened. It
offered the following eight overarching recommendations, and more specific
recommendations for items 2-8.
Recommendation 1: Conduct regular assessments of performance measures to determine
whether available resources allow more ambitious goals.
Recommendation 2: Improve the mechanisms by which requests for HHEs are sought and
prioritized to include a broader array of requests from a wider variety of requestors.

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Recommendation 3: Ensure that recommendations in HHEs are relevant, feasible,
effective, and clearly explained.
Recommendation 4: Use the HHE Program to develop occupational health professional
resources.
Recommendation 5: Develop a proactive, comprehensive information-transfer strategy
for HHE Program outputs with better approaches to reaching wider audiences, including
traditionally underserved populations.
Recommendation 6: Develop more extensive formal linkages and mechanisms with other
parts of NIOSH, CDC, and HHS to enhance the capacity for involvement in policyrelevant impacts.
Recommendation 7: Initiate formal periodic assessment of new and emerging hazards.
Recommendation 8: Continue to provide guidance and recommendations during public
health emergencies.
HHE Program staff disseminated the NA report within NIOSH and announced its
availability on the NIOSH website and through NIOSH e-News.

3 Implementation Plan
3.1 Purpose
The Implementation Plan summarizes actions taken, underway, or planned in response to
the NA recommendations. The Implementation Plan supports the HHE Program goals
identified above and is integrated with the HHE Program Strategic Plan.

3.2 Development Process
We held group meetings to discuss the NA recommendations, brainstorm response
options, and develop specific strategies and activities. We also sought input from others
in NIOSH, including the HHE Cross-sector Steering Committee, a group comprised of
HHE Program partners and stakeholders from other NIOSH programs. HHE Program
managers presented the Implementation Plan to the NIOSH BSC at a meeting in August
2009; the BSC provided comments at a meeting in December 2009 and in a written report
in March 2010. We also posted the Implementation Plan on the NIOSH website for
public comment. Two comments were received.

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3.3 External Factors
External factors contribute to the dynamic environment in which the HHE Program
operates. Untold factors influence whether the Program receives requests for HHEs when
health hazards are present in a workplace. These factors relate to awareness of the HHE
Program, incentives for submitting requests (e.g., free services available to small business
owners), disincentives to submitting requests (e.g., employees’ fear of reprisals by their
employers, employers concerns about the public availability of the HHE report),
acknowledgement in the workplace that a problem might exist, and legal limits on the
authority of the Program. Numerous factors also influence whether workplace changes
are made in accordance with HHE Program recommendations. These factors relate to
economic realities in individual workplaces, attitudes about health and safety in the
workplace, labor-management relations, and regulatory requirements, among others. In
all, these factors require that Program enhancements and new initiatives remain in
balance with available resources. Integrating the Implementation Plan into the annual
strategic planning process provides opportunities to adjust annual goals and performance
measures, as needed, to meet shifting needs and priorities.

3.4 Vision
In addition to being responsive to the specific recommendations of the NA, the
Implementation Plan reflects the NA’s vision for the HHE Program of the future.
According to the NA vision, the HHE Program “would serve to identify heretofore
unrecognized workplace hazards, as well as known hazards for which permissible
exposure limits or other control measures appear inadequate.” In keeping with this vision,
among other efforts, the HHE Program of the future would:
 Continue to emphasize activities unique to NIOSH, e.g., combining medical,
industrial hygiene, epidemiologic, and toxicologic techniques
 Expand its role in training occupational health professionals
 Be more well known in the workplace and in the occupational health community
 Be recognized by local, state, and national agencies and organizations as a
primary resource when health problems arise in the workplace
To fully attain this vision, the HHE Program will require additional resources and active
engagement of its partners and stakeholders.

4 HHE Program Response to the NA Recommendations
4.1 Overview
We discuss the 34 specific NA recommendations according to their role in the HHE logic
model (Figure 1, Page 27). Because many recommendations are interrelated, with
separate recommendations sharing common concepts, this approach allows for common
themes to emerge and shows how HHE Program enhancements will ultimately affect the
impact of the HHE Program on occupational health.

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Table 2 (Page 20) lists the recommendations according to the logic model structure and
notes the following additional information:
 status of NIOSH efforts to implement the recommendation
 parties who need to be involved in implementation
 a relative sense of the need for additional resources to implement the
recommendation. Absolute numbers are not provided because further input and
discussion are needed to identify options, evaluate their relative merits, and
characterize their feasibility. The resource designation considers both personnel
costs and discretionary funding.
Based on this information, we developed the following scheme to classify the activities
described in the Implementation Plan:
 Group A: Activities the HHE Program can do alone, or with limited partner
involvement, with few new resources
 Group B: Activities needing partners and moderate new resources
 Group C: Activities needing partners and significant new resources

4.2 Inputs
4.2.1 Improving the triage of HHE requests
(See Table 2, Page 20)

4.2.1.1 NA Recommendations
The NA noted that the triage process, while generally efficient, needs more structure and
explicit criteria.
Recommendation 2b: Implementing, as part of the triage process, a formal technical
assistance mechanism to help requestors to formulate valid HHE requests. In cases where
an HHE is not appropriate or where resource limitations prohibit an investigation,
technical assistance should include referral to more appropriate NIOSH divisions or
government agencies.
Recommendation 2c: Development of an explicit, written process for classifying and
prioritizing HHE requests. Priority should be based on the gravity of the potential harm,
the number of employees potentially at risk at similar workplaces or using similar work
processes, the urgency of the problem, the potential to assess health outcomes, and the
possibility of identifying emerging issues. Potential impact on standards and policy
should also enhance the priority of an HHE request in the triage process. Relationship of
the HHE to current research may be considered, but should not be the only or primary
factor. The process should provide guidance on weighting these varying factors.
Recommendation 2d: Better formalizing of the triage process, including the identification
of needed expertise, and improving the transparency of the process to HHE requestors,
while maintaining flexibility and speed.

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4.2.1.2 NIOSH Response
We recognize that the decisions we make about how we respond to HHE requests can
influence the HHE Program’s relevance and impact. Based on the definitions given
above, we classify activities in this area as Group A (HHE program alone, or with limited
partners, with few new resources). In response to the NA recommendations, we have
refined our triage criteria based on need, authority, and mitigating factors (Appendix A)
and will incorporate this information into the HHE Program Procedures Manual. Guided
by these criteria, HHE Program staff will continue to use professional judgment (with
input, as needed from others in NIOSH) to make the best decision for each specific
situation. Often it is not possible to predict the outcome of a field investigation in terms
of the balance between resources expended, information gained, and public health actions
taken. Additionally, unlike programs whose priorities and planned projects may be set for
one or multiple years, the HHE Program works in a more fluid manner over a shorterterm planning horizon. We adjust our decisions based on the nature of incoming HHE
requests and available resources. A request for a specific issue might receive a low
priority one year, but at a later time a similar request might receive a higher priority
based on external factors and internal conditions and priorities.
To better communicate this information to potential HHE requestors, we will post a plain
language summary of the decision criteria on the HHE Program website. We believe this
addition will promote accountability and provide information for citizens about what
their Government is doing. Improved communication with the public also will be
accomplished by other website enhancements, such as adding a frequently asked
questions section, a means to provide input to the HHE Program, and a means to request
assistance in formulating and submitting HHE requests. The concept of an interactive
website has been discussed by HHE Program staff and continues to be an area of interest.
We have committed resources to website enhancement, with work continuing throughout
Fiscal Year 2010.

4.2.2 Expanding the base from which HHE requests are received
(See Table 2, Page 20)
While acknowledging a lack of information about whether the needs of underserved
populations and small businesses are being met by the HHE Program, the NA noted the
need for the Program to elicit a broader array of HHE requests.

4.2.2.1 NA Recommendations
Recommendation 2e: Establishment of formal relationships with organizations
representing underserved populations, small businesses, and their employees.
Recommendation 2f: Enhancing HHE Program outreach to OSHA national and regional
offices and to state health and labor departments to better communicate the functions and
activities of the HHE Program, increase cooperation with these agencies, and provide
more complete and timely feedback.

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Recommendation 6d: Pursuit of a change in the HHE Program’s legislative and
regulatory authority to improve the capacity to identify hazards in need of HHEs,
improve the ability to gain entrance to facilities when requested by treating physicians or
community representatives, and address exposure other than chemical agents.
Recommendation 7a: Evolve from a program that passively receives requests to a
proactive program that seeks opportunities for field investigations.

4.2.2.2 NIOSH Response
The changing economic, social, cultural, and political landscape in the United States
means that we must reach out to new populations. To remain relevant and address high
priority needs, the HHE Program relies on a steady volume of HHE requests from a broad
base that is representative of our Nation’s working population. Historically, the Program
has been mostly passive with regard to seeking HHE opportunities. We envision
becoming more active in creating opportunities to increase awareness of the HHE
Program and strategically encouraging submission of HHE requests. A significant
increase in the number of HHE requests, however, could strain resources and impair our
ability to respond in a timely manner. HHE Program managers will evaluate the
effectiveness of proactive efforts and monitor their impact on staff workload and
timeliness.
The following three groups are mentioned throughout the NA report and arise in several
places in the HHE Program’s logic model:
 Underserved populations
 Small businesses
 Other government agencies (e.g., the Occupational Safety and Health
Administration (OSHA), state labor departments, state health departments)
The approach to working with these groups varies, as does the need for resources and
partnerships. The likelihood of significant success, particularly in the next 5 years also
varies.
We have increased outreach to other government agencies. We classify activities in this
area as Group B (HHE Program and partners with moderate new resources). Two new
activities are now underway. We initiated an informal partnership with OSHA Region I
to increase awareness of the HHE Program among its field staff and help them identify
appropriate opportunities to make referrals and encourage the submission of HHE
requests. This effort, in its infancy, may provide a model that can be expanded. We also
began a collaborative effort with the NIOSH Adult Blood Lead Epidemiology and
Surveillance (ABLES) Program to increase awareness of HHE services among the 40
ABLES Program state-based partners. The early concept for this effort is to identify a
subset of state partners who have active lead surveillance programs with limited internal
resources, particularly in the area of industrial hygiene. These states will be assigned an
HHE Program liaison for technical support and to encourage the submission of
appropriate HHE requests to evaluate workplaces from which elevated blood levels were
reported. This effort is particularly timely given the recent decision of the Council of
State and Territorial Epidemiologists to change the case definition for reporting elevated

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adult blood lead levels from 25 micrograms per deciliter or greater to 10 micrograms per
deciliter or greater. This new requirement will likely bring many more facilities to the
attention of public health agencies. Other activities that will be considered include direct
outreach to state labor departments operating OSHA-approved occupational safety and
health programs and geographically targeted outreach to local health departments.
We are exploring ways to reach out to small businesses, and classify activities in this area
as Group C (HHE Program and partners with significant new resources). We have
established a working relationship with the NIOSH Small Business Assistance and
Outreach Program. The two Programs have taken steps to explore opportunities with
Chambers of Commerce in the Cincinnati metropolitan area. We believe that this is likely
to be a long-term effort. In the near term we are following up on a recently completed
customer survey focused on small businesses. We surveyed a national sample of
businesses with fewer than 250 employees in the food manufacturing sector and the
building services sector. We plan to follow the survey with focus groups to provide more
in-depth information about concerns, needs, and issues affecting small businesses and
their involvement with the HHE Program. We will combine this information with other
inputs to develop a targeted marketing campaign to increase awareness of the HHE
Program. Our success in the two sectors initially selected will provide lessons that can be
applied more broadly.
Since a pilot project in 2002-2004 to develop partnerships with Hispanic community
organizations in the Cincinnati, Ohio, area, we have not begun new efforts to reach out to
underserved populations. We classify activities in this area as Group C (HHE Program
and partners with significant new resources) and, likely, the most challenging new
undertaking. Our previous efforts have given us insights into issues affecting underserved
populations and have demonstrated the low likelihood that increased awareness alone
will lead to a meaningful increase in requests for HHE services. Legal, cultural, and
economic barriers are significant impediments to meeting the needs of underserved
populations, particularly low wage, immigrant, temporary, and contract workers. We will
maintain a dialogue with the NIOSH Occupational Health Disparities Cross-sector
Program, to help us understand and evaluate possible approaches to working with
underserved populations.
To some extent, changing the HHE Program’s legislative and regulatory mandate would
contribute to the goal of increased access to the HHE Program for the groups discussed
above. By giving NIOSH authority to conduct investigations based on requests from
individuals or organizations other than employees and employers, underserved
populations would have more voices speaking on their behalf and requesting HHE
Program assistance. Additionally, expanding NIOSH authority to address a broader range
of hazards, including physical hazards in general industry, would also allow us to reach
some sectors of the population currently outside the scope of the Program. We welcome
the opportunity to begin a dialogue about this issue within NIOSH. We have begun to
compile a list of issues and options and, with guidance from the NIOSH Director, will
evaluate the impact of this recommendation. We classify this activity as Group C.

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4.2.3 Increasing opportunities to recognize emerging issues
(See Table 2, Page 21)

4.2.3.1 NA Recommendations
Recommendation 2a: Systematic use of professional meetings, scientific conferences,
scientific literature, and surveillance data, including those generated by NIOSH, to assist
in prioritizing field investigations and recognizing emerging issues.
Recommendation 3c: Debriefing in NIOSH after site visits and report dissemination for
determination of relevance and impact on a systematic basis (potentially missed
opportunities to identify emerging health hazards could also be identified).
Recommendation 7b: Develop systematic approaches to identify hazards where OSHA
permissible exposure limits are inadequate or nonexistent, to identify unknown hazards,
and to identify known hazards encountered under new circumstances.
Recommendation 7c: Establish and periodically review a tickler file of inconclusive or
unexpected evaluation results to determine whether new trends or problems may be
emerging.
Recommendation 7d: Periodically meet with intramural and extramural research
scientists and stakeholders in government, academe, labor, and industry to discuss
specific unresolved evaluations, to review aggregate findings, and to solicit input about
new or emerging hazards or interventions.

4.2.3.2 NIOSH Response
Our activities with respect to emerging issues can be viewed from two perspectives: (1)
HHEs uncovering emerging issues and (2) HHEs providing descriptive data about
emerging issues identified by others. We classify activities in this area as either Group A
(HHE program alone, or with limited partners, with few new resources) or Group B
(HHE Program and partners with moderate new resources).
HHEs uncovering emerging issues. This can occur when the HHE Program receives a
request and, in the course of responding, documents a newly discovered hazard or a
known hazard in a new or previously overlooked population. Generally, such issues are
readily apparent at the completion of an evaluation. A recent example is the recognition
of bronchiolitis obliterans related to flavoring chemicals used in the manufacturing of
popcorn. For these situations, timely dissemination of HHE findings is essential. In some
HHEs, however, emerging issues may not be immediately apparent due to the small size
of the investigated work force or the lack of scientific tools to fully evaluate the situation.
Periodically reviewing the findings from investigations with unresolved problems is one
activity that may help bring unrecognized hazards to light. We are working with the
OSHA Office of Occupational Medicine to establish a tickler file of unresolved cases
from both agencies. These cases will be reviewed by staff from the agencies, who will
share information internally and with professional colleagues at scientific meetings and
through electronic discussion groups.

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Field staff from federal OSHA, state agencies with OSHA-approved programs, and state
and local health departments can also be a source of leads to uncover previously
unrecognized emerging issues. Since the numbers of these staff far outweigh the number
of HHE investigators, their presence in the workplace can help identify emerging
hazards. This will require that the OSHA and state field personnel are aware of the HHE
Program and know when it is appropriate to make a referral or encourage the submission
of an HHE request. The new collaboration with OSHA Region I to increase awareness of
the HHE program among its field staff is one step in this direction. To ensure that the
state programs are engaged, we recently participated in a meeting of the Occupational
Safety and Health State Plan Association and will continue to look for opportunities with
this organization. We also will explore opportunities with public health organizations
such as the Council of State and Territorial Epidemiologists and the National Association
of County and City Health Officials.
HHEs providing descriptive data about emerging issues already identified. Enhanced
identification of emerging issues requires a framework and systematic approach that
encompasses many NIOSH programs. This process is closely intertwined with NIOSH
efforts to develop more robust surveillance systems for occupational diseases and
workplace hazards. Ensuring that the HHE program gives priority to emerging issues
requires knowing what those issues are. The HHE program will seek to learn about
existing resources to identify emerging issues, such as the Risk Observatory of the
European Agency for Safety and Health at Work. When emerging issues are known, the
HHE program can actively seek opportunities to explore such issues or can give priority
to requests we receive. This can occur when we actively seek opportunities to explore
such issues or when we receive unanticipated requests. A recent example is the
collaboration between the HHE Program and other NIOSH researchers to evaluate the
potential hazards related to the increasing use of orthopthalaldehyde to sterilize certain
equipment in healthcare settings. As more focus is put on surveillance data across
NIOSH, and data about occupational illnesses and health hazards becomes more
comprehensive and accessible, it will be possible to see if this new information is helpful
in targeting HHE Program resources.

4.2.4 Preserving program resources during emergencies
(See Table 2, Page 22)

4.2.4.1 NA Recommendations
Recommendation 8a: Remain diligent by working with NIOSH management to avoid
negative impact on routine activities of the HHE Program as a result of emergency
response activities.
Recommendation 8b: Develop a mechanism, such as the enlistment of help from training
program participants and alumni, to ensure continuation of routine operations in the
absence of staff involved in emergency response.

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4.2.4.2 NIOSH Response
In the nearly 2 years since we prepared the documentation for the NA review, the
situation with regard to emergency response activities in the HHE Program has continued
to evolve. Presently, we do not believe that new activities are needed in this area. We
will, however, remain vigilant to ensure that HHE Program resources are appropriately
protected and the integrity of the traditional mission of the HHE Program is maintained.
We classify activities in this area as Group A (HHE program alone, or with limited
partners, with few new resources).
In the immediate aftermath of the World Trade Center and anthrax responses, CDC and
NIOSH created new programs to better support responses to terrorist activities, natural
disasters, and emerging infectious diseases. Leadership for and coordination of
emergency response and preparedness, a task that in the past fell in large part to the HHE
Program, now resides in the NIOSH Emergency Preparedness and Response Office. Over
time, this has resulted in less frequent and less intense reliance on the HHE Program to
support field activities, provide subject matter experts, and staff the emergency
operations center. Because of training coordinated by HHE Program staff, other NIOSH
field staff now can be called on for emergency response activities. As a result of these
efforts, we believe we can better manage resources internally to ensure that critical,
routine HHE functions are not affected significantly. In the event, however, of a largescale national emergency, it is possible that we would be asked to become more involved.
In this situation, shifting a portion of personnel resources away from routine HHEs may
become necessary; we view this as an appropriate public health action. HHE Program
management would continue to provide a timely assessment of incoming requests to
ensure that urgent situations receive an appropriate response. In addition, information
about temporary shifts in Program resources would be communicated to stakeholders to
maintain transparency in HHE Program operations. Former HHE Program staff now
working in other parts of NIOSH, of which there are many, could assist in meeting urgent
needs. Compared to bringing in HHE alumni now working in the private sector, this
approach would be simpler to implement due to legal limitations when using non-NIOSH
employees in field investigations.

4.3 Outputs
4.3.1 Enhancing the quality and helpfulness of HHE reports
(See Table 2, Page 23)

4.3.1.1 NA Recommendations
Recommendation 3a: Explanation of the relevance, feasibility, and impact of each
recommendation in the text of HHE reports.
Recommendation 3b: Priority-setting among recommendations in all reports to indicate
those requiring immediate action in the targeted workplace.
Recommendation 3e: Enhancement of internal quality assurance by development of a
formal program. Consider external review of a sampling of recent reports and technical

11

Attachment D: HHE local health department survey, Implementation Plan

assistance letters for scientific content, report completeness, and appropriateness of
recommendations.
Recommendation 4b: Tracking and mobilizing the extensive talent and commitment
represented in the HHE Program-trained occupational health workforce. A network of
HHE Program alumni could be fostered to help to develop HHE opportunities. A
program-level advisory board could assist the Program in leveraging resources, serve a
recruiting and retention function, assist in identifying emerging issues, and provide expert
advice.

4.3.1.2 NIOSH Response
HHE reports are the primary output of the HHE Program and provide a basis for most
other Program outputs. As such, we are committed to ensuring that the reports are of the
highest quality and meet the needs of our stakeholders. Although HHE reports are used
by a diverse group of stakeholders, the primary audience remains employers and
employees at investigated facilities. Activities related to the HHE report quality are
considered Group A (HHE program alone, or with limited partners, with few new
resources).
We have changed the recommendations section of the standard HHE report in response to
the NA recommendation. We developed standard structure and content for the
recommendations that focuses on the well-accepted concept of a hierarchy of controls.
The new information included in HHE reports clearly addresses situations where shortterm actions (such as use of respiratory protection) are needed while longer term
solutions (such as installation of engineering controls) are evaluated and implemented.
The new information also gives a brief explanation of each class of actions in the
hierarchy and offers a rationale for these actions. Although it is essential that HHE
investigators become familiar with the facilities they investigate and understand the
implications of their recommendations, a thorough evaluation of feasibility generally is
outside the scope and expertise of the HHE Program. We added new language to HHE
reports recommending that a health and safety committee with management and labor
representatives form a working group to discuss the HHE report findings and
recommendations, including their feasibility. As appropriate, during followback visits,
we will look for opportunities to discuss financial considerations and cost-benefit
calculations as they relate to our recommendations. We will maintain a dialogue with
other NIOSH researchers to ensure that opportunities for collaboration are identified.
We will continue to maintain a rigorous internal review process and explore efficient
ways of incorporating interactions with other NIOSH programs as part of the process.
Our review process is designed to ensure scientific quality, consistency with NIOSH
policy, and responsiveness to the needs of the HHE requestor. The review process also is
intended to ensure that recommendations made by HHE investigators are supported by
their findings. To augment this process, as recommended by the NA, we will begin a pilot
effort to assess the feasibility and value of having an external quality assurance process
that involves evaluating a sample of HHE reports after they are issued. We will provide
evaluation guidelines much like is done for manuscripts submitted to peer-reviewed

12

Attachment D: HHE local health department survey, Implementation Plan

journals. Potential reviewers will be chosen to represent the scientific disciplines
appropriate for each report and the perspectives of different types of stakeholders
(including the business and labor communities). These reviewers will be drawn from the
newly developed network of HHE Program alumni (as described below). This new
quality assurance process will be evaluated at the end of 2 years by HHE Program staff
with input from participating reviewers. The evaluation will consider the following
program attributes:
 Ability to obtain volunteer reviewers
 Timeliness of the reviews
 Reviewers’ assessment of the HHE Program’s guidance
 Extent of program resources used to maintain the program
 Value of the information derived from the reviews
The HHE Program has created an alumni network using online social media tools. We
have created a database of former HHE Program staff, EIS officers, other fellows, guest
researchers, and short-term domestic and international visitors, and are continuing to
populate the database with information about their professional area(s) of expertise,
former role in the HHE Program, current affiliation, and contact information. When we
have contact information, we have invited these individuals to participate in the alumni
network. Participants in the network may be asked to assist and provide input in various
ways, including the following:
 Offering opinions about HHE Program policies and procedures
 Providing technical review of investigation protocols
 Providing quality assurance evaluation of HHE reports and other documents
 Acting as an ambassador to increase awareness of the HHE Program among
potential program requestors
 Helping to disseminate HHE program products
 Identifying emerging issues for which HHEs would be useful
We hope that participants find benefit from the alumni network as a way of connecting
with other occupational health professionals and by enhancing their contributions to
occupational safety and health through participation in a national program.

4.3.2 Expanding opportunities to train occupational health
professionals
(See Table 2, Page 23 )

4.3.2.1 NA Recommendations
Recommendation 4a: Increased recruitment of new investigators from universities, the
Epidemic Intelligence Service, the Commissioned Officer Student Training Extern
Program, occupational medicine residencies, Education and Research Centers (ERCs) for
Occupational Safety and Health, and state and local health departments into HHE
Program training rotations. This will require ongoing development of more attractive
training, mentoring, and rotations.

13

Attachment D: HHE local health department survey, Implementation Plan

Recommendation 4c: Engagement and use of ERCs and other university-based training
programs to involve trainees in HHE field investigations.
Recommendation 4d: More formal collaboration with ERC faculty and other extramural
researchers to assist in field investigation, dissemination, and training opportunities.

4.3.2.2 NIOSH Response
We are cognizant of the role the HHE Program plays in the training of occupational
health professionals. Based on the response of the NA review committee, we have added
a new strategic goal in this area. Because expansion of these efforts is not feasible
without significant new resources, however, we consider most activities related to
training as Group C (HHE Program and partners with significant new resources).
With current resources, we are taking some new steps to strengthen training activities.
These include:
 Developing a more formal curriculum for trainee rotations
 Opening up training opportunities beyond our traditional partners to include
others with applicable training programs such as the Veterinary Public Health
Program at The Ohio State University.
 Reaching out to the NIOSH ERCs to increase awareness of the HHE Program. In
particular, the NIOSH Denver Office is working closely with the new Colorado
ERC to identify opportunities for trainees to participate in HHE field
investigations.

4.4 Transfers
4.4.1 Improving dissemination channels and developing partnerships
to enhance dissemination
(See Table 2, Page 24)

4.4.1.1 National Academies Recommendations
Recommendation 5a: Use innovative techniques to reach small businesses and
underserved populations, creating a broad array of mechanisms for communicating with
diverse constituencies and attending to issues of literacy, language, and national-origin
barriers. The effectiveness of applied outreach should be evaluated in a formal manner.
Recommendation 5b: Improve the searchability of the online HHE search engine by
developing a list of standardized key words (an alphabetized list of hazards and diseases
would be beneficial).
Recommendation 5c: Develop distribution mechanisms that are not internet-dependent to
complement internet distributions.

14

Attachment D: HHE local health department survey, Implementation Plan

Recommendation 5d: Disseminate HHE results more broadly to groups likely to be
affected, including distribution of HHE reports in the geographic regions where
investigations are conducted.
Recommendation 5e: Increase efforts to compile compendia of findings (such as those
developed for isocyanates, noise, tuberculosis, and lead) when generalized processoriented findings can be gleaned from the experience of the HHE Program in a variety of
settings.
Recommendation 5f: Develop improved methods of outreach to stakeholders so that
workers and workplaces affected by new and emerging occupational health problems will
be alerted quickly.
Recommendation 5g: Supplement program outreach efforts by using community and
small business groups to translate HHE results and finding for their constituencies.
Recommendation 6c: Continued regular use of the NORA sector councils and the NIOSH
Board of Scientific Counselors to disseminate information about the HHE Program.
Recommendation 5h: Leverage existing NIOSH, Centers for Disease Control and
Prevention, and Department of Health and Human Services resources to enhance
technology transfer.

4.4.1.2 NIOSH Response
Many of these recommendations focus on the same groups discussed above in terms of
increasing outreach to enhance awareness of the HHE Program:
 Underserved populations
 Small businesses
 Other government agencies (e.g., OSHA, state labor departments, state health
departments)
Thus, the efforts previously described will not only lead to better recognition of the
Program and the services it can provide but these efforts also will open up new channels
for disseminating HHE Program findings. Because the efforts in these areas are varied,
we classify them individually and they fall into Groups A, B, and C.
In the short-term, we plan to give priority to the following areas in which we are involved
directly and have available expertise:
 Improving access to HHE reports on the HHE Program website. The ability to
retrieve HHE reports by industry sector will added to the NIOSH website. Our
next steps will be to expand this concept for other commonly used criteria such as
state, health outcome, or nature of the exposure. As part of this effort, we have
begun the process of making all numbered HHE reports available electronically;
many reports before about 1985 are now available at no cost from the HHE
Program upon request. In another effort, we have established a partnership with
the International Journal of Occupational and Environmental Health. The Journal

15

Attachment D: HHE local health department survey, Implementation Plan

is now publishing selected HHE investigation summaries, which are included in
PubMed.
 Increasing production of written materials for dissemination through on-line and
print trade publications.
 Developing HHE summary documents on priority topics as identified in the
NIOSH Program Portfolio. Currently, we are updating the document summarizing
HHEs related to noise exposure and hearing loss, which was published in 1999.
Since that time nearly 60 new HHE reports on this topic have been released.
 Using the findings from our customer survey to develop new communication
channels for reaching small businesses.
Other efforts addressing new dissemination channels and methods of outreach and
leveraging resources will rely on efforts of others in NIOSH. Similarly, efforts by the
NIOSH Office of the Director to streamline processes for creating and disseminating
NIOSH documents will benefit the HHE Program. Improved communication internally
through the NIOSH Program Portfolio may prove beneficial to the HHE Program in this
regard.

4.5 Intermediate Outcomes
4.5.1 Establishing partnerships with government programs that can
use HHE-generated information
(See Table 2, Page 25 )

4.5.1.1 National Academies Recommendations
Recommendation 6a: Promotion and increase in direct communication, especially with
OSHA and state occupational safety and health agencies.
Recommendation 6b: Alerts to NIOSH and CDC about HHEs that are relevant to policymaking outside the CDC system.

4.5.1.2 NIOSH Response
HHE Program partnerships to increase awareness of the HHE Program for the purposes
of facilitating new HHE requests will also serve to enhance transfer of HHE-generated
information. We classify our activities in these areas as Group A (HHE program alone, or
with limited partners, with few new resources). In addition to the activities discussed
previously, HHE Program staff participates in an ongoing, regularly scheduled NIOSHOSHA issues exchange meeting.
NIOSH continues to look for and take advantage of opportunities to share information
about the HHE Program with others throughout CDC and outside the CDC system, when
warranted. For example, we recently released a report on exposure to environmental
tobacco smoke among casino dealers in Las Vegas; we communicated with the CDC
Office of Smoking and Health about this report; they were keenly interested in
disseminating it to their stakeholders. We also included information about this report in a
briefing for the CDC Director. We also shared the report with the public health

16

Attachment D: HHE local health department survey, Implementation Plan

association in several states and , to date, two (New Jersey and Ohio) have posted an
announcement about it on their website. In another example, NIOSH issued a press
release about the release of an HHE report on occupational radiation exposure to airport
baggage screeners.
The DHHS Secretary is informed regularly of NIOSH activities determined to have
significant visibility and, or, impact. HHE reports are routinely provided to OSHA and
state health agencies. Through enhance communications with various OSHA offices, we
have improved distribution of HHE reports to state plan states and to federal agencies.

4.6 Program Evaluation
4.6.1 Evaluating various aspects of the program formally and
regularly
(See Table 2, Page 25)

4.6.1.1 National Academies Recommendations
Recommendation 1: Conduct regular assessments of performance measures to determine
whether available resources allow more ambitious goals.
Recommendation 3d: Modification of the followback surveys for use in assessing the
relevance, feasibility, and impact of recommendations.
Recommendation 5i: Evaluate, in a formal manner, the effectiveness of information
transfer programs, including knowledge transfer to employers and employees not
investigated.

4.6.1.2 NIOSH Response
We are committed to an annual review of the HHE Program strategic plan. We classify
activities in this area as Group A (HHE program alone, or with limited partners, with few
new resources). As resources expand or contract, and external demands change, the
annual goals and performance measures will be adjusted. HHE Program supervisors have
begun to more effectively use milestones and project tracking management tools that can
provide information useful for adjusting the strategic plan. We are mindful of the NA
recommendation to develop more ambitious goals and continue to look for opportunities
to use our resources more efficiently. For example, producing an HHE compendium
document on a specific topic (Recommendation 5e) may allow us to respond without a
field investigation to a greater number of requests concerning that topic. This may also be
the case as better information is obtained from the HHE followback program about the
effectiveness of specific recommendations (Recommendation 3d).
Over the next 3-5 years, we will increase the number of onsite followback evaluations.
We believe that this offers the best approach to gathering valid and comprehensive
information about our recommendations. We classify this activity as Group B (HHE
Program and partners with moderate new resources). Recently, we identified a senior

17

Attachment D: HHE local health department survey, Implementation Plan

staff member to lead this effort and have involved our health communications specialist.
They are trying a variety of approaches to garnering cooperation from employers in the
followback efforts; this effort presents many challenges for which new approaches will
be needed. They have had preliminary discussions with staff involved in the NIOSH
Economics Cross-sector Program and will continue to share information that may help
identify opportunities for research related to economic aspects of feasibility. We plan to
use the followback information to make improvements to the HHE Program. We also
plan to use the information to develop and disseminate case studies describing 1)
approaches that work and do not work in protecting worker health when hazards have
been identified and 2) ways of overcoming barriers to implementing HHE Program
recommendations.
Evaluating the effectiveness of information transfer programs, particularly for facilities
not investigated by the HHE Program, reaches beyond the scope and resources of the
HHE Program. We classify this activity as Group C (HHE Program and partners with
moderate new resources). Other NIOSH efforts, however, can contribute valuable
information. For example, questions about familiarity with the HHE Program were part
of a recent survey of labor and trade associations and the results will be shared with us.
The NIOSH Research to Practice (r2p) initiative focuses on the transfer and translation of
research findings, technologies, and information into effective prevention practices and
products that are adopted in the workplace. When resources become available through
this effort and other Institute-wide dissemination and evaluation efforts, we will seek
opportunities for partnership to explore this aspect of HHE information transfer.

18

Attachment D: HHE local health department survey, Implementation Plan

Table 1. Strategic and Intermediate Goals of the HHE Program1
1. Strategic Goal. Prevent occupational illnesses through reduced exposure to workplace
hazards
1.1. Intermediate goal: Increase the number of health hazard evaluation requests
concerning important occupational health problems.
1.2. Intermediate goal: HHE Program resources are focused on high priority
problems
1.3. Intermediate goal: Develop and maintain state-of-the-art investigative,
analytic, and communication tools.
1.4. Facilitate implementation of recommendations at facilities investigated
through the HHE Program
1.5. Provide appropriate technical assistance for health hazard evaluation requests
addressed without a field visit
1.6. Intermediate goal: Employees and employers at facilities not investigated
through the HHE Program are aware of hazards identified and controls
recommended by HHE Program investigators
1.7. Intermediate goal: Professional practices, guidelines, policies, standards, and
regulations are influenced by information generated from the HHE Program
2. Strategic Goal. Promote occupational safety and health research on emerging issues
2.1. Intermediate goal: Stakeholders have information about emerging issues
2.2. Intermediate goal: HHE program managers and investigators are informed
about emerging hazards
3. Strategic Goal. Partners and customers have the information they need regarding high
priority occupational health issues likely to arise during public health emergencies
3.1. Intermediate goal : Partners and customers have the information they need
regarding high priority occupational health issues likely to arise during public
health emergencies
3.2. Intermediate goal: HHE Program personnel respond appropriately to requests
for assistance
4. Strategic Goal. Train physicians, nurses, industrial hygienists, and other professionals
to address workplace health hazards from a practical, public health perspective
through HHE field experiences
4.1. Intermediate goal: Education and Research Centers provide information to
new occupational health and safety trainees about HHE Program
opportunities, including EIS Program and NIOSH rotations
4.2. Intermediate goal: Academic training centers request training for occupational
health professionals

19

Attachment D: HHE local health department survey, Implementation Plan

Table 2. Overview of Recommendations

Recommendation
(as numbered in the NA report)
2b
Implement a formal mechanism to
help requestors to formulate valid
HHE requests or to make
appropriate referrals.
2c
Develop an explicit process for
classifying and prioritizing HHE
requests.
2d
Better formalize the triage process
and improve its transparency to
HHE requestors.
2e
Establish formal relationships with
organizations representing
underserved populations, small
businesses, and their employees.

Status
Well
underway

Status
Just
begun

Status
Not yet
begun

Who?
HHE

Improving the triage of HHE

Who?
HHE +
Internal
Partners

Who
HHE +
External
Partners
requests (4.2.1)

Few
Resources

Moderate
Resources

Significant
Resources

Group1







A







A







A

Expanding the base from which HHE requests are received (4.2.2)
















C

1

A: HHE program alone, or with limited partners, with few new resources; B: HHE + partners, moderate new resources; C: HHE + partners, significant new
resources

20

Attachment D: HHE local health department survey, Implementation Plan

Recommendation
(as numbered in the NA report)
2f
Enhance outreach to OSHA and to
state health and labor departments to
better communicate HHE functions
and activities and to increase
collaboration.
6d
Pursue a change in the HHE
Program’s legislative and regulatory
authority to improve capacity to
identify hazards in need of HHEs,
ability to gain entrance to facilities,
and ability to address exposures
other than chemical agents.
7a
Evolve from a program that
passively receives requests to a
proactive program that seeks
opportunities for field investigations
2a
Use professional meetings,
surveillance data, etc. to assist in
prioritizing field investigations and
recognizing emerging issues.
3c
Conduct internal debriefings after
site visits and report dissemination to
systematically assess relevance and
impact, and identify emerging
hazards.

Status
Well
underway

Status
Just
begun

Status
Not yet
begun

Who?
HHE

Who?
HHE +
Internal
Partners



Who
HHE +
External
Partners











Few
Resources



Moderate
Resources

Significant
Resources

Group1



B









Increasing opportunities to recognize emerging issues (4.2.3)


























21

Attachment D: HHE local health department survey, Implementation Plan

Recommendation
(as numbered in the NA report)
7b
Develop systematic approaches to
identify hazards where OSHA
permissible exposure limits are
inadequate or nonexistent, unknown
hazards, and known hazards in new
circumstances.
7c
Establish and periodically review a
tickler file of inconclusive or
unexpected evaluation results to
determine whether new trends or
problems may be emerging.
7d
Periodically meet with intramural
and extramural research scientists
and stakeholders to discuss
unresolved evaluations, review
aggregate findings, and solicit input
about emerging hazards or
interventions.
8a
Work with NIOSH management to
avoid negative impact on routine
activities as a result of emergency
response activities.
8b
Develop a mechanism to ensure
continuation of routine operations in
the absence of staff involved in
emergency response.

Status
Well
underway

Status
Just
begun

Status
Not yet
begun



Who?
HHE

Who?
HHE +
Internal
Partners

Who
HHE +
External
Partners



Few
Resources

Moderate
Resources



Significant
Resources

Group1


























Preserving program resources during emergencies (4.2.4)

























22

Attachment D: HHE local health department survey, Implementation Plan

Recommendation
(as numbered in the NA report)
3a
Explain the relevance, feasibility,
and impact of each recommendation
in HHE reports.
3b
Set priorities among report
recommendations to indicate those
requiring immediate action in the
targeted workplace.
3e
Enhance quality assurance by
developing a formal external review
program for a sampled of recent
reports and letters.
4b
Track and mobilize HHE Program
alumni to assist in leveraging
resources, help with recruitment and
retention, assist in identifying
emerging issues, and provide expert
advice.
4a
Increase recruitment for training
rotations; develop more attractive
training, mentoring, and rotations.
4c
Use ERCs and other universitybased training programs to involve
trainees in HHE field investigations.

Status
Well
underway

Who?
Who
HHE +
HHE +
Internal
External
Partners
Partners
Enhancing the quality and helpfulness of HHE reports (4.3.1)
Status
Just
begun

Status
Not yet
begun

Who?
HHE





Few
Resources





Moderate
Resources

Significant
Resources

Group1


























Expanding opportunities to train occupational health professionals (4.3.2)






























23

Attachment D: HHE local health department survey, Implementation Plan

Recommendation
(as numbered in the NA report)

Status
Well
underway

Status
Just
begun

Status
Not yet
begun

Who?
HHE

Who?
HHE +
Internal
Partners

Who
HHE +
External
Partners

Few
Resources

Moderate
Resources

4d
Collaborate more formally with ERC
faculty and other extramural



researchers to assist in field
investigation, dissemination, and
training.
Improving dissemination channels and developing partnerships to enhance dissemination (4.4.1)
5a
Use innovative techniques to reach
small businesses and underserved



populations; formally evaluate
outreach efforts.
5b
Improve the searchability of HHE



reports online.
5c
Develop distribution mechanisms



that are not internet-dependent.
5d
Disseminate HHE results more
broadly to affected groups, including



distribution in the geographic
regions where investigations are
conducted.
5e
Increase efforts to compile




compendia of findings.
5f
Develop improved outreach methods
to alert affected workers and


workplaces quickly of new
occupational health problems.



Significant
Resources

Group1




















24

Attachment D: HHE local health department survey, Implementation Plan

Recommendation
(as numbered in the NA report)

Status
Well
underway

Status
Just
begun

Status
Not yet
begun

Who?
HHE

Who?
HHE +
Internal
Partners

Who
HHE +
External
Partners

Few
Resources

Moderate
Resources

5g
Supplement outreach efforts by
using community and small business


groups to translate HHE results and
finding for their constituencies.
5h
Leverage NIOSH, CDC, and DHHS



resources to enhance technology
transfer.

6c
Regularly use NORA sector councils
and the NIOSH Board of Scientific



Counselors to disseminate
information.
Establishing partnerships with government programs that can use HHE-generated information (4.5.1)
6a
Increase direct communication with


OSHA and state occupational safety
and health agencies.
6b
Alert NIOSH and CDC about HHEs



that are relevant to policy-making
outside the CDC system.
Evaluating various aspects of the program formally and regularly (4.6.1)
1
Conduct regular assessments of
performance measures to determine


whether available resources allow
more ambitious goals.




Significant
Resources

Group1















25

Attachment D: HHE local health department survey, Implementation Plan

Recommendation
(as numbered in the NA report)
3d
Modify the followback surveys to
assess the relevance, feasibility, and
impact of recommendations.
5i
Formally evaluate the effectiveness
of information transfer programs.

Status
Well
underway

Status
Just
begun

Status
Not yet
begun

Who?
HHE





Who?
HHE +
Internal
Partners


Who
HHE +
External
Partners

Few
Resources





Moderate
Resources

Significant
Resources



Group1





26

Attachment D: HHE local health department survey, Implementation Plan

Figure 1. Health Hazard Evaluation Program Logic Model

27

Attachment D: HHE local health department survey, Implementation Plan

Appendix A – Revised Criteria for Field Investigations
Need
NIOSH gives highest priority for field investigations regarding serious health effects that
are plausibly related to current workplace exposures or conditions. Priority decreases
with decreasing severity of the health effects and/or plausibility of the relationship to
workplace exposures or conditions.
NIOSH gives higher priority for field investigations to new and emerging issues and
lower priority to well known problems for which appropriate guidance information is
readily available. The latter includes most concerns relating to indoor environmental
quality and mold in nonindustrial buildings. For the majority of these requests, our
extensive experience enables us to provide assistance by telephone and correspondence.
While investigations potentially affecting large numbers of workers are generally given
higher priority, when other criteria are met, NIOSH may initiate a field investigation even
when the number of workers is small.
1.

What is the gravity of the potential workplace health hazard? (listed in order of
decreasing priority)
a. Potentially life-threatening hazard
b. Medical conditions diagnosed by a health care provider
c. Symptoms suggestive of a recognized medical condition
d. Nonspecific symptoms that are not common in the general population
e. Nonspecific symptoms that are common in the general population

2.

How likely is it that current exposures or conditions are causing, or could cause, a
serious health problem?
a. Are exposures or conditions known to cause serious adverse health effects?
b. Are exposures or conditions not known to cause serious adverse health effects
but could plausibly do so, based on established principles of occupational
medicine, industrial hygiene, toxicology, and other relevant disciplines?

3.

Is the number of workers exposed to the hazard at this facility or at other facilities
likely to be large? While investigations potentially affecting large numbers of
workers are generally given higher priority, when other criteria are met
(specifically need and legal authority), NIOSH may initiate a field investigation
even when the number of workers is small.

Authority
NIOSH gives highest priority to situations in which it has clear authority to initiate a
workplace investigation.

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1. Does the request meet the statutory and regulatory requirements? A request that does

meets all of the following requirements:
a. Is submitted in writing; and
i. Is signed by the employer, three current employees (unless three or
fewer are exposed to the potential health hazard), or an employee
representative (as defined in 42 CFR 85)
ii. Identifies a specific workplace(s) where the potential hazard exists
iii. Concerns a workplace covered by the Occupational Safety and Health
Act or Executive Order 12196 of February 26, 1980, "Occupational
Safety Programs for Federal Employees”
iv. Concerns a workplace covered by the OSHAct and the hazard is a
substance or concerns a workplace covered by the MSHAct and the
hazard is a substance or physical agent

When a request does not fall within the parameters of the Occupational Safety and
Health Act or Mine Safety and Health Act, and NIOSH determines that there is a
need for a field investigation, it proceeds as follows:
 When the request is from another government agency and that agency
has the legal authority to enter the workplace, NIOSH will proceed with
an investigation by providing technical assistance to the requesting
government agency and entry will be under that agency’s authority.
 In the following circumstances, NIOSH will proceed with an
investigation with the consent of all parties involved
i. When (i) and (ii) are met, but (iii) or (iv) are not
ii. When the request is from another government agency and that
agency does not have legal authority
Mitigating Factors
NIOSH gives higher priority when 1) no other resources are available to address the
concerns, 2) it has the tools and approaches to address the concerns, or could acquire or
develop the tools and approaches in a timely manner, and 3) the concerns relate to
ongoing government priorities and activities
1. Is other, more appropriate, assistance available?
2. Does NIOSH have the tools and approaches to assess the concerns, or could they be

acquired or developed in a timely manner?

3. The concern has been identified by NIOSH or other entity as an emerging hazard.
4. Are the concerns of current high national interest or related to ongoing national or

international priorities and activities? NIOSH is more likely to proceed with a field
investigation if any of the following apply:

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Attachment D: HHE local health department survey, Implementation Plan

b. The concerns are in an industry or occupational group, or relate to a health
outcome or exposure, identified as a priority in the National Occupational
Research Agenda
c. The concerns are in an industry or occupational group, or relate to a health
outcome or exposure, identified as a priority by the Occupational Safety and
Health Administration
NIOSH generally will defer a field investigation if the workplace is the subject of an
ongoing inspection by OSHA or state OSH agency for similar issues to those raised in
the HHE request.
5. When the above considerations have been addressed, NIOSH may consider other

factors. NIOSH is more likely to conduct a field investigation when the following
circumstances apply.
a. The task producing the hazard is present continuously or most days, rather
than intermittently or sporadically.
b. A problem has been documented, but efforts to address it have not been
successful.
c. Action has been requested by a member of Congress or the Executive Branch.
d. A field investigation would provide training opportunities for NIOSH staff,
staff of other government agencies, or students involved in occupational
health training programs.

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