Between-User Reliability of Tier 1 Exposure Assessment Tools Used Under REACH

When applying simple screening (Tier 1) tools to estimate exposure to chemicals in a given exposure situation under the Registration, Evaluation, Authorisation and restriction of CHemicals Regulation 2006 (REACH), users must select from several possible input parameters. Previous studies have suggested that results from exposure assessments using expert judgement and from the use of modelling tools can vary considerably between assessors. This study aimed to investigate the between-user reliability of Tier 1 tools. A remote-completion exercise and in person workshop were used to identify and evaluate tool parameters and factors such as user demographics that may be potentially associated with between-user variability. Participants (N = 146) generated dermal and inhalation exposure estimates (N = 4066) from specified workplace descriptions ('exposure situations') and Tier 1 tool combinations (N = 20). Interactions between users, tools, and situations were investigated and described. Systematic variation associated with individual users was minor compared with random between-user variation. Although variation was observed between choices made for the majority of input parameters, differing choices of Process Category ('PROC') code/activity descriptor and dustiness level impacted most on the resultant exposure estimates. Exposure estimates ranging over several orders of magnitude were generated for the same exposure situation by different tool users. Such unpredictable between-user variation will reduce consistency within REACH processes and could result in under-estimation or overestimation of exposure, risking worker ill-health or the implementation of unnecessary risk controls, respectively. Implementation of additional support and quality control systems for all tool users is needed to reduce between-assessor variation and so ensure both the protection of worker health and avoidance of unnecessary business risk management expenditure.