Sunday, December 31, 2017

New Year, New Industrious Hygienist

Sincere apologies for the months-long delay between posts. I don't really have an excuse, except the last few months have been busy with work, writing, and attempting to learn how to use my new manga markers. I'm stuck trying to figure out what this blog should become, now that I'm not consulting anymore. 

  • Is it yet another "life as a professor" blog? (meh, we don't really need more of those) 
  • Is it me trying to become a manga artist and posting my awful art that slowly becomes better and more my style? (maybe, but the internet doesn't deserve that right now)
  • Is it more sock puppets? (these take a ton of work/time, so I hope not)
  • Is it (please say it isn't) another "I want to be a writer, so I'm writing about writing instead of actually finishing my own work" blog? (nope)
  • Is it my random thoughts on safety and human factors? (sometimes, probably)

When I figure out what this blog is, I'll feel a bit less anxious about it just sitting on the internet, gathering a tiny amount of views. I'm more or less over drawing the Industrious Hygienist (#industrioushygienist) mangas for now. While there are a ton of consulting malarkey stories I still need to tell, I'm not a good enough manga-ka right now to do them justice. Plus, as I've noted before, I'm still slow at the drawing, inking, and coloring, so each 8.5"x11" page takes me 6 to 8 hours from start to finish. Currently, I don't have that kind of time on the weekends. 

My point of pride for the end of the year: I went on a Naruto (#naruto) and Bleach (#bleach) anime spree over winter break. I'll blame the fact that I was sick for 8 days right after winter break started and I'd submitted grades for my classes. Trying to figure out the jutsu hand seals while hopped up on Day-Quil is ... funny and surprisingly difficult. Turns out that I am not very coordinated on cold medication. It was strange to try and explain to my parents and grandparents that I was not just "watching cartoons" and this is completely normal behavior for adults in Japan.

As is my habit, I like to spend New Year's Eve doing something I don't normally have time to do, while pondering how the year went. I started out drawing one of my characters from a short story, but it somehow became a manga of me. I didn't realize it until I was drawing the necklace, so that was sort of weird, but nice to be in the "flow" of the art. The new markers are fun to use!

The Industrious Hygienist in her "professor" look.
Yes, that is a flannel shirt - we're in the PNW, after all.

In 2017, I accomplished or learned the following: 

  • I'm officially a published author - thanks to @dreamingrobotpress for their awesome 2018 Young Explorer's Adventure Guide and the opportunity to share my short story, "On the Lam on Luna" with middle grade readers.
  • I submitted another short story yesterday to the 2019 Young Explorer's Adventure Guide. It was co-written by me and the exceptional spouse, and is awesome. We hope they like it. 
  • I started a doctorate in March 2017 and have completed 3 classes so far. It's a Doctor of Education (Ed.D.) in Health Professions from A.T. Still University. I have all A's so far, but am dreading the quantitative analysis (statistics) course.
  • I started my second year of working as an Assistant Professor of Safety and Health Management at Central Washington University. Contrary to what I believed last year, the second year has not been easier and I've been working harder than ever. 
  • I bought almost 4 hours of J-pop music (mostly songs from Fullmetal Alchemist: Brotherhood, Naruto, Bleach, and Vampire Knight) and have the tunes and sounds memorized. Now on to trying to learn some Japanese.
  • I bought a new oven (ours died a slow death) and am not worried about giving myself food poisoning from undercooked food anymore. 
  • I started exercising at least four times a week, getting up at 5:30am to be ready for work by 8:00am. Imagine me on a mini-trampoline, watching anime while I jump around like a goofball. I've been boxing too, which is a very satisfying experience.
  • Over the summer, I completed the first draft of a historical fiction novel co-written by me and the exceptional spouse. The spouse has it now, and after a merry game of tug of war about whether I would give him the actual manuscript to track changes on, he is making edits and finding ways to improve the scenes. More on this when it is done and ready for Kindle...
  • I spoke at Safety 2017 (annual professional development conference for the American Society of Safety Engineers) with a colleague. Our proposal to speak was not accepted for 2018, so I'll be staying home from conferences next year. I plan to spend the entire summer writing, drawing, and playing the piano, violin, and clarinet. Maybe a little bit of class preparation, but only enough to not feel stressed when fall quarter starts again.

There are probably some other things that I've forgotten to list, but those are the big ones. My realistic goals for 2018 are to: 1) keep getting A's in my doctorate classes, 2) finish the historical fiction book(s), 3) keep exercising, 4) take a real vacation with the exceptional spouse, and 5) figure out what this blog is going to be. Perhaps I'll also determine my manga style and get better at drawing with some more practice. 

Saturday, September 9, 2017

New manga markers!

For my birthday, I bought myself some new manga markers with the Amazon gift card my parents gave me. I am so excited to learn how to use them! I also bought some new manga paper to see how it differs from the multipurpose computer paper I usually use.

Things purchased:


Rather than be reasonable and practice in short sessions with the markers and paper, I dove in and recreated one of my favorite panels from my other favorite manga/anime: Vampire Knight. It turned out better than I anticipated, so I decided to post it as a new milestone in my mangaka journey.


Some notes:
  • Yup, I am aware the Day Class uniforms are black. At the moment, I only have a weird mix of primary colors and grays. No black marker in the set. So I improvised with blue! Same with Yuki's hair color, improvised with the sienna brown marker I have. 
  • Character names are Zero and Yuki, brought to you by the incredible Matsuri Hino
  • Therefore, this is fan art...while I try to figure out my own style. 
  • The paper I purchased does NOT let you erase once you have inked, so I'll be looking for a different long-term paper. Hence the pencil marks.

I hope you enjoy the new art, which will be posted sporadically as I find time on weekends between teaching, my doctorate studies, and life in general.

Yuki and Zero from Vampire Knight.

I anticipate that my own art and characters will be a hybrid of Hiromu Arakawa + Matsuri Hino + Hayao Miyazaki, since they are the artists I enjoy the most.  

Tuesday, September 5, 2017

TSCA and Exposure Assessment: Risk Evaluation

This post is a continuation of the series on TSCA and exposure assessment. Today’s topic is risk evaluation, including the prioritization process for EPA.

15 CFR 53 Part 2605 explains how, once the U.S. Environmental Protection Agency (EPA) Administrator determines that a chemical substance or mixture presents a risk, the Administrator can apply one or more requirements to the substance.

The requirements can include:
  • A prohibition or limitation restriction on manufacturing, processing, or distribution of the substance
  • A prohibition or limitation on manufacturing, processing, or distribution of a substance for a particular use or concentration in excess of a level set by the Administrator
  • A requirement for the substance or mixture to be marked with warnings and instructions with respect to use, distribution, and/or disposal – the form and content of these warnings is prescribed by the Administrator
  • A requirement to maintain records associated with the manufacturing process and tests used to assure compliance with TSCA
  • A requirement prohibiting or regulating any commercial use of a substance
  • A requirement prohibiting or regulating any manner or method of disposal of a substance, or of any article containing the substance (applies to manufacturers, processors, and commercial use)

The EPA has released a risk-based screening process which will be explained in detail in a later post, but basically delineates chemical substances and mixtures as high-priority or low-priority. Only high-priority substances undergo risk evaluation at this time, and this is anticipated to a be a 3- to 3.5-year process. EPA must consider the hazard and exposure potential of the substance, including persistence and bioaccumulation, susceptible subpopulations, storage near drinking water sources, and whether there are conditions of use or volumes that are of concern.

A chemical substance submitted to EPA should have prioritization conducted within 9 months to 1 year. EPA will start with the chemical substances previously identified in the TSCA chemical work plan and then move on to other chemicals. EPA has 3.5 years to start conducting risk evaluations on 20 other high-priority substances, with preference given to chemicals on the 2014 update of the TSCA chemical work plan that are persistent, bioaccumulative, carcinogenic, or toxic (acute or chronic effects).

An interesting quote from 15 CFR 53 Part 2605 (b)(2)(c): “The Administrator shall continue to designate priority substances and conduct risk evaluations […] at a pace consistent with the Administrator to complete risk evaluations […]” (emphasis added). So, basically, EPA gets to set its own pace on this. 

Another interesting requirement is that risk evaluations of metals and metal compounds must use the Framework for Metals Risk Assessment of the EPA’s Office of the Science Advisor (2007) or its successor document.

The requirements for a risk evaluation are identified as:
  • Integrate and assess available information on hazards and exposures for the conditions of use of the substance (considering risk of injury to health or the environment and susceptible subpopulations)
  • Describe whether aggregate or sentinel exposures to a chemical substance under the conditions of use were considered, and the basis for that consideration
  • Not consider costs or other non-risk factors
  • Take into account the anticipated duration, intensity, frequency, and number of exposures under the conditions of use
  • Describe the weight of scientific evidence for the identified hazard(s) and exposure(s)

“Aggregate” and “sentinel” exposures are not defined in the regulation. EPA further complicates this by using “aggregate” and “cumulative” in their website about exposure assessment tools being used.
  • Aggregate = considers combined exposures to a single stressor across multiple routes and multiple pathways
  • Cumulative = evaluates combined exposure to multiple stressors via multiple exposure pathways

The American Chemistry Council (ACC) had these same concerns in their response letter to EPA, recommending that EPA consider including “definitions of both aggregate and sentinel exposures in the proposed regulation so the regulated community will understand how EPA intends to apply the terms, and to ensure consistency and regularity in application.” ACC provided the following definitions for clarification:
  • Aggregate = combined exposure for one substance over multiple exposure pathways from multiple difference sources (similar to definition given above)
  • Sentinel = the exposure that is judged to cause the plausible upper-bound individual human exposure to a substance of interest within a broad category

When the EPA completes a risk evaluation, the Administrator should consider and publish a statement based on “reasonably available information” with respect to:
  • Effects of the chemical substance on health and magnitude of exposure of human beings
  • Effects of the chemical substance on the environment and magnitude of exposure of the environment
  • Benefits of chemical substance (for various conditions of use)
  • Reasonably ascertainable economic consequences of the rule, including the effect on the national economy, small business, technological innovation, the environment, and public health, as well as the costs/benefits of the regulatory action and the cost effectiveness of the regulatory action

This is seemingly contradictory, since the risk evaluation is supposed to be conducted without consideration of costs, but the final risk evaluation must consider costs and other economic consequences…it also requires the Administrator to consider if there are technically and economically feasible alternatives available before releasing a final rule on a substance.

In my next post, I’ll explain the risk evaluation process for TSCA. Future posts will include the following topics:
  • Imminent hazards in TSCA
  • Reporting requirements of TSCA
  • Research aspects of TSCA
  • How TSCA handles confidential information
  • Citizen’s civil actions and petitions in TSCA
  • Employee protection and TSCA effects on employment
  • How test methods will be developed and evaluated for TSCA
  • ReachScan: the exposure assessment model
  • Using predictive methods to assess exposure 
  • New chemical exposure limits under TSCA