The only time I saw a rule that enforced the 25 class-size was in New Jersey by the Public Employees OSHA (PEOSHA).  They set up an incredibly effective right to know program in about 1985 with mandatory yearly training.  The initial training was 4 hours.  Refreshers were two hours.  There were mandatory tests after each. The tests and sign in sheets were kept by the employer and those sheets could not contain more than 25 students at a time.  The program was so good that after 5 or 6 years of this regular training, I could walk into a class of 25 custodians and they would already understand concepts like synergistic exposures. 

 

And PEOSHA was a tiger.  When they found out that Rutgers art department had never done their training some 3 years after they were required to do it, they stopped classes.  No teacher could teach until they had done their 4 hours and passed the test. I was one of the two trainers that worked two days morning and afternoon to get all of the faculty and staff trained.  I still smile when I think of those grumbling teachers who actually had to apply themselves and pass the test.  So don't tell me that enforcement doesn't work either.

 

One of the most brilliant parts of the NJ training was a requirement that the trainer provide an MSDS on an actual product they use and to compare the information on that MSDS with the information from NJ Health Department's fact sheets on the same chemicals. And those fact sheets also tell workers when chemicals have NOT been tested for toxic effects as well. So every employee left KNOWING that most MSDSs suck and that if they really want to know about those ingredients, the answers were only a click away. 

 

You might want to check out "NJ right to know hazardous chemical fact sheets" if you don't already know about them.  And like California's health department, NJDOH proactively looks at research and makes their own determinations about which chemicals are carcinogens.

 

But like all training rules that actually work, it had to come to an end.  In 1993 when Governor Whitman (of later EPA infamy) came into office she started chopping away at the PEOSHA and environmental programs in the state.  I stopped doing the new post-Whitman training which was every two years, short, less effective, and enforcement was limited.  It was no fun anymore.

 

But I feel privileged to have seen that training and enforcement really can work. 

 

 

Monona Rossol, M.S., M.F.A., Industrial Hygienist

 

 

-----Original Message-----
From: David C. Finster <dfinster**At_Symbol_Here**WITTENBERG.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Mon, Apr 14, 2014 10:31 pm
Subject: Re: [DCHAS-L] Class sizes