Page/
Paragraph |
Error |
Correction |
*Informed
Jan/2013 |
4/1 |
Job tasks (the industrial hygiene perspective); |
Job tasks (the epidemiology perspective); |
Yes |
4/1 |
Periodically updated; |
Continuously (almost daily) updated; Published quarterly; |
Yes |
4/2 |
Lack of transparency in data sources; |
Data sources listed and methods published in AJIM; |
Yes |
4/2 |
Lack of weight-of-evidence criteria for agent-disease
links; |
See response to question #1 in 2nd
Meeting Questions. |
Yes |
4/2 |
Overreliance on textbooks; |
This is an opinion. What is the evidence? |
|
4/2 |
Information may be neither comprehensive nor up to date; |
No examples given; |
|
5/1 |
Has ambiguous criteria for identifying agent-disease
links; |
Ignored my presentations of SHE(O)s & DiseasesbyCat.doc;
See slides 15-18 in 1st
Meeting Presentation. |
Yes |
6/1 |
Delays in updating links in Haz-Map and thus in SEM; |
See p. 63, paragraph 2: ". . . this is an acceptable
time frame for updates." |
|
6/3 |
Weight-of-evidence approach critical; |
Already used in Haz-Map for cancers; The best attempt to
use this approach for noncancer diseases was the SHE(O)s
published by NIOSH in 1991, which is the foundation and precursor of
Haz-Map |
Yes |
6/3 |
Inclusion of citations would enhance utility; |
The DOL
response to the IOM report says, "The
Haz-Map database does contain source references to each link that is in
that database;" |
Yes |
6/3 |
Peer review increases public confidence; |
Probably the most used database of chemicals is the NIOSH
Pocket Guide. It is not peer reviewed. Neither is the ACGIH Documentation
of TLVs and BEIs. |
|
6/3 |
Peer review increases accuracy & comprehensiveness; |
There are many examples of peer-reviewed papers of poor
quality. |
|
6/3 |
Peer review ensures current information; |
This is not necessarily true, e.g., if the reviewers meet
only once a year. |
|
7/1 |
TOXLINE, IRIS, and NTP would supplement Haz-Map. |
These databases already used, especially HSDB; Haz-Map
includes all relevant chemicals in HSDB. IRIS and NTP cover only a few
hundred chemicals that are also covered in better databases like ATSDR
and ACGIH. |
|
7/3 |
Use of references in Haz-Map not systematic/comprehensive; |
Any examples? What is the evidence for this opinion? |
|
7/3 |
NTP toxicology reports not used at all; |
Many references to NTP; Haz-Map includes NTP cancer
designations (not published by NLM but in ExPub version); |
Yes |
7/3 |
OEHHA is a good resource for occupational toxicology; |
According to the department description accessed from the
home page, its mission is to assess health risks of environmental
contaminants. It works with the Dept. of Pesticide Regulation to protect
applicators. No other occupational toxicology mentioned; |
|
7/3-8/1 |
These experts use weight-of-evidence approach to conclude
toxicity; |
This is done for cancer only. For noncancer diseases, I
see no such approach in the most important databases: NIOSH, ACGIH,
ATSDR, CAMEO, CHRIS, HSDB, ICSC, IDLH, and EXTOXNET. |
|
8/3 |
Not transparent because citations to evidence not
included; |
The DOL
response to the IOM report says, "The Haz-Map database does contain source references to each link that is in
that database;" |
Yes |
8/4 |
Quality-control review will ensure accuracy; |
Inspection does not ensure quality; See page
by Institute of Healthcare Improvement. |
|
12/2 |
It is difficult to determine the evidence base for the
noncancer agent/disease links. |
See the second and third paragraphs of my
"Summary" on page 4 of Jan.
2013 response. |
Yes |
12/3 |
There is no peer-review of Haz-Map. |
See the first paragraph of my "Summary." See
slide #34 in 1st
Meeting Presentation. |
Yes |
25/2 |
Author is board certified in occupational medicine; |
No mention of MPH degree or 2 year fellowship in
occupational medicine; |
Yes |
Table 2-1 |
Adverse Effects |
Names of adverse effects are mixed up with categories of
adverse effects. |
Yes |
31/2 |
REPROTOX not available online; |
Available online by subscription; Of the 36 online
books and databases, 29 are free. |
Yes |
31/4 |
No transparent selection criteria for journals used in
review; |
There is a list of journals used for each review. The ones
selected contained the most useful articles in the 2002 journal review. |
Yes |
42/3 |
No details on what constitutes a consensus; |
See details on my website pages: "Bronchitis,
chronic" and "Renal Diseases." |
Yes |
42/3 |
No details on what evidence reviewed in making links; |
Did you read the Haz-Map website? See Pneumoconioses,
Toxic Pneumonitis, Pulmonary
Fibrosis, Occupational Asthma, Allergic
Contact Dermatitis, Toxic Hepatitis, and Methemoglobinemia. |
Yes |
42/3 |
No details on good industrial hygiene; |
Each Haz-Map agent is linked to any of 54 industrial
processes in which exposure may occur. Each disease is linked to any of
227 high-risk job tasks in which sufficient
exposure may occur to cause the disease. |
Yes |
43/1 |
No rules to determine if sufficient evidence for causal
links; |
This was explained in the 2nd and 3rd paragraphs of my
"Summary" in the Jan. 2013
response. What rules are needed to link lead to lead poisoning or
carbon monoxide to chemical asphyxiation? See slide # 23 Metals
and Occupational Diseases. |
Yes |
44/3 |
Does not consider animal & mechanistic data; |
Of course, all toxicology data is considered, but a
chemical that causes disease in animal ingestion experiments does not
necessarily cause disease in workers exposed by skin or inhalation
routes. |
Yes |
46/2 |
Haz-Map not reviewed by anyone at NLM for accuracy, bias,
and comprehensiveness; |
If true, then why did the department that publishes TOXNET
invite me to publish Haz-Map? See slide #35 in 1st
Meeting Presentation |
Yes |
46/5 |
Haz-Map relies heavily on 3 textbooks. |
Why does the committee mention only 3 books when the
content is loaded with references from many journals, databases, and
over 20 main textbooks? |
Yes |
47/1 |
Haz-Map cites only IARC for cancer designations. |
Haz-Map also includes ACGIH and NTP. These 2 fields are
not yet published by NLM but they are published in the ExPub version of
Haz-Map. |
Yes |
47/2 |
References are not accessible. |
Of the 36 online
books and databases, 29 are free. Of my 21 main textbooks, all are
for sale on amazon.com (April 3, 2013). |
Yes |
77/2 |
IOM-recommended sources use weight-of-evidence approach; |
Yes, for cancer; No such approach for noncancer diseases
is used in ACGIH, ATSDR, NIOSH, or OSHA. |
|
Table 3-1 |
The NIOSH Pocket Guide is an authoritative source. |
This book has no references! Henry Chan, CIH was the
technical editor. It was first printed in 1978. "The data were
collected from a variety of sources . . ." According to the
website, it is updated periodically. |
|
81/3 |
IARC Group 1 is only criteria used by Haz-Map for
determining cancer links. |
The committee acknowledges on page 43, paragraph 2 that
the "Occupation" chapter by Siemiatycki
et al. is also used. A link requires Group 1 + occupational exposure. |
Yes |
Table 3-3 |
Shows "Chloramphenicol," an antibiotic, as
causing disease; |
Could cause leukemia by ingestion or injection, but not
after occupational exposure; |
|
87/4 |
Occupational cardiovascular disease not clear in Haz-Map; |
See More Research Needed. |
|
88/1 |
These CNS effects are different from "encephalopathy,
chronic solvent." |
According to "Solvent Neurotoxicity" by FD Dick,
"Solvents, such as styrene, may cause sub-clinical colour vision
losses." See PMID: 16497867 for free full-text article. |
|
96/3 |
Haz-Map lacks clear weight-of-the evidence approach. |
What weight-of-evidence approach did the committee use to
make Table 3-4? |
|
100/1 |
NTP OHAT toxicology reports are an important resource absent from Haz-Map. |
The website on April 3, 2013 showed only 20 chemical
profiles of which 3 were drugs. |
|