NCHR Comments on the Proposed Data Collection Submitted for Public Comment and Recommendations

October 6th, 2023, in response to CDC's draft guidance on information collection regarding thermal spray coating, NCHR recommends that CDC improve the language of the survey questions to enhance study design and better inform occupational health standards.

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October 6th, 2023

We appreciate the opportunity to comment on the Center for Disease Control and Prevention (CDC) proposed information collection regarding the project titled Exposures, Health Effects, and Controls of Chemicals from Thermal Spray Coating (TSC).

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.

We appreciate the effort of the CDC and NIOSH to develop new knowledge by administering research in the field of occupational safety and health and to provide that knowledge into practice in order to promote occupational safety and health.  We agree that it is important to better understand work practices and controls related to metals, particles, and gases generated during thermal spray coating and to identify areas for potential intervention. This is a necessary measure in the absence of sufficient epidemiologic and exposure studies to understand the effect of TSC processes, exposures, and related health effects. For example, there is increasing evidence of the risk of severe lung damage and other potential harms to workers due to inhalation of specific chemicals as well as particulate matter. These and other risks need to be studied in order to prevent injuries and deaths.

We have two suggestion regarding the draft survey:

1. The wording of some questions might be confusing, if the person completing the survey is unclear if questions directed to “you” refers to the individual completing the survey or the company. For example, the question “Has your volume of TSC work increased over the last 5 years?” could be understood as referring to the individual or to the company.  This should be clarified.
2. Questions about quantity should include information about the number of people involved in the work. For example, the question “About how much time is spent daily on TSC processes?” would provide important additional information if it also asked how many employees were involved in these TSC processes and/or approximately how much time was spent by each of the individuals who were most engaged in this work.

We encourage CDC and NIOSH to follow up this collection of information with well-designed safety research as soon as possible.^1,2

References:

1. Washington State Department of Labor and Industries. (2005). How to Protect Workers While Thermal Metal Spraying, by Safety & Health Assessment & Research for Prevention (Report # 69-3-2005). Tumwater, WA: Washington State Department of Labor.
2. Antonini, J. M., McKinney, W. G., Lee, E. G., & Afshari, A. A. (2021). Review of the physicochemical properties and associated health effects of aerosols generated during thermal spray coating processes. Toxicology and industrial health, 37(1), 47–58. https://doi.org/10.1177/0748233720977975

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