Industrial Hygienists Urge Exposure Assessment of Legacy Asbestos Uses, Naloxone Programs
By Abby Roberts
Most OEHS professionals are aware of EPA’s final rulemaking on chrysotile asbestos, just as most know about the nationwide opioid crisis. However, presenters of an AIHA Connect pop-up session on May 20 urged attendees to consider overlooked aspects of both events that may affect individual workplaces. First, Lindsey Malek, MS, CIH, an industrial hygienist with Exxon Mobil Corporation, advised the audience to start collecting data on exposures to legacy uses of asbestos at their facilities, before EPA opens a public comment period on its proposed risk management rules for legacy uses of asbestos. Then, Mary-Catherine Goddard, MPH, CIH, an industrial hygienist with the design firm Arcadis, spoke on developing workplace programs for administering naloxone, a life-saving medication that can reverse the effects of an opioid overdose.
Malek began with an overview of the second part of EPA’s risk evaluation of asbestos, finalized in November 2024, which addresses legacy uses of asbestos. Initially, the agency’s risk evaluation had just focused on chrysotile asbestos, the only form of asbestos permitted to be imported in the U.S. before May 2024. A 2017 court decision held that the agency must also consider legacy uses of asbestos, applications for which production has ended but that remain in buildings and facilities. Malek explained that asbestos was used to insulate operation envelopes in the oil and gas industry from the industry’s beginnings in the late 19th century until EPA banned asbestos insulation in 1975. Many of these facilities are still in operation—the oldest still-operational refinery in the U.S. started up in 1881. According to Malek, these refineries are kept safe through maintenance and asbestos abatement as needed. Nonetheless, Part 2 of EPA’s risk evaluation found that legacy uses of asbestos contributed to unreasonable risk to workers and occupational non-users.
Malek described how ExxonMobil had sought to get a head start on collecting data related to asbestos exposures at its facilities, although she did not anticipate EPA to open a public comment period on proposed risk management rules to address this unreasonable risk until late 2026. Because the agency had observed a lack of data on exposures to legacy asbestos uses among occupational non-users, who work in facilities containing asbestos but don’t handle the substance, ExxonMobil conducted a study on exposures to these workers. Malek summarized sampling and analysis using methods employed by NIOSH, as well as the results, which she said demonstrated effective management of asbestos exposures by the company.
Malek stressed that it’s up to OEHS professionals in the oil and gas industry to collect necessary data to inform EPA’s risk management decisions and that it’s better for companies to prepare this before the comment period is announced. “Do it now,” she urged. “Understand the impacts. Industry advocacy is very critical.”
Goddard introduced her presentation on naloxone awareness in the workplace by briefly outlining the devastating effects of the opioid overdose epidemic. A person can die from an opioid overdose if their brain receives inadequate oxygen, but administering naloxone can restore normal breathing in two or three minutes. First responders carry an injectable form of naloxone, but the medication is also available as an over-the-counter nasal spray under the brand name Narcan. Each nasal spray device contains a single dose of medication suitable for adults or children. Naloxone is a safe medication and will not cause harm if administered to a person not experiencing an opioid overdose, Goddard explained.
She cited a survey by the National Safety Council, which found that although most employers want to support employees experiencing substance use disorders, many lacked the necessary resources. Goddard recommended that for organizations consider naloxone programs to evaluate whether their workforce is at risk. For example, workers who perform manual labor and repetitive tasks are more likely to become injured, which may lead to them being prescribed opioids, putting them at risk for substance misuse and abuse. Organizations should also examine whether evidence of drug use has been observed at work sites, whether first responders can reach the work site in time to prevent deaths from overdose, and whether members of the public may enter the work site.
If an organization decides there is a risk of opioid overdose in the workplace, Goddard stressed that implementing a naloxone program requires commitment at all levels of an organization. OEHS professionals will likely manage the program but will probably work alongside human resources and legal departments, as well as employees trained to administer naloxone. Organizations should also research legal liability. Good Samaritan laws exist in most jurisdictions, but nuances vary. The organization should develop a written policy for the naloxone program, which can be integrated into emergency response procedures. The medication must be purchased and stored, either refrigerated or at room temperature, in a place where it can be easily accessed. Employees must also be trained in recognizing the signs of an opioid overdose and in administering naloxone.
Goddard closed her session by providing a selection of resources on naloxone programs from NIOSH, NSC, and the Narcan website.
Abby Roberts is assistant editor of The Synergist.
Read more coverage of AIHA Connect 2025.
