The general aim of this study is to critically evaluate the implementation of the training and medical surveillance (MS) provisions of the Occupational Safety and Health Administration's (OSHA) 1984 Ethylene Oxide (EtO) Standard in the hospital setting. The broader goal of this research is to identify strengths and weaknesses of training and MS implementation in substance-specific OSHA standards in order to provide for more effective practice, enforcement strategies, and policy-making in these areas. The study will begin with extensive descriptive data gathering on EtO training and MS implementation patterns as well as levels of compliance with training and MS requirements. Implementation and compliance patterns will be related to organizational and workforce characteristics to identify determinants which are most closely correlated with desirable patterns of training and MS. Our estimates of compliance with EtO standard training and MS provisions will be compared to OSHA Integrated Management Information System inspection data in order to judge the utility of this database for the study of training and MS implementation and compliance. The following three specific hypotheses, derived directly from the implementation strategies of exposure monitoring-driven substance-specific health standards will be tested: (1) Exceedance of trigger exposure levels is positively associated with implementation of EtO training, and (2) exceedance of trigger exposure levels is positively associated with implementation of EtO medical surveillance. Two EtO exposure levels are specified to trigger training and MS requirements: the Action Level of 0.5 ppm Time-weighted Average (TWA) and the Excursion Limit of 5 ppm TWA per 15 period. We are asking to what extent employers are in compliance with these requirements and to what extent exposure monitoring specifically guides employers in the implementation of EtO training and MS. Hypothesis (3): The implementation of training is positively associated with the implementation of medical surveillance. As stated in current OSHA policy, part of the intent of training is to make workers aware of their rights under a standard, which in turn is presumed to make workers more likely to exercise those rights. We will test for an association which would be consistent with a such a causal relationship between training and MS. In addition to the presence or absence of training, we will also relate training frequency, quantity, and type to MS implementation, allowing some inferences about relative training effectiveness. To achieve the specific aims, our approach integrates theory and principles from occupational health, health education, and the social sciences with survey research methodology.
