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Previous by Date: Subject: Re: OHSA/NIOSH Permissible limits Date: Sat, 4 Dec 2010 23:04:54 +0000 Author: "Kohler, Christopher E" |
Next by Date: Subject: Re: OHSA/NIOSH Permissible limits Date: Sat, 4 Dec 2010 18:34:37 -0500 Author: "Wright, Mike" |
Note that California has a defined process built into their statutes to review and revise airborne OSHA PELs for the State. California appears to be the only state that does this review and revision on a regular basis using a dual voluntary advisory committee approach. The process is public and involves all interested stakeholders. A PEL recommendation is advanced by a Health Expert Advisory Committee and is then reviewed for implementation issues by a Feasibility Assessment Committee. Not a perfect process, but it does help make California PELs more in line with current literature and industrial hygiene practice than the 1968 based Federal PELs.
As a result, California enforceable PELs are often times lower (significantly) than the Federal OSHA PELs and in some cases California PELs are lower than the ACGIH TLVs. This should be considered when writing and reviewing MSDS and when setting company occupational exposure limits and action limits.
with regards,
Mike
Michael N. Cooper MS, MPH, CIH
Senior Managing Scientist
Exponent® / Failure Analysis Associates
149 Commonwealth Drive, Menlo Park, CA 94025
( TEL
+650 688-1760 7 FAX +650
688-1799 CELL +408
313-2127
Email: mcooper**At_Symbol_Here**exponent.com
From:
DCHAS-L
Discussion
List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of
ACTSNYC**At_Symbol_Here**CS.COM
Sent: Saturday, December 04, 2010 9:19 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] OHSA/NIOSH Permissible
limits
Chris, et al.,
Just two more fast comments and then, uncharacteristically, I'll shut
up.
1. Rob asked for documentation about OSHA's opinion of their
PELs.
The statement is the Federal Register at 58 FR 35337-35351, June 30,
1993 when
OSHA had to formally reinstate the old PELs thus revoking both the
upgraded
levels and addition of new PELs on substances for which there were no
standards
in 1968:
"OSHA continues to believe that many of the old limits which it
will now
be enforcing are out of date (they predate 1968) and not sufficiently
protective of employee health based on current scientific information
and
expert recommendations. In addition, many of the substances for which
OSHA has
no PELs present serious health hazards to employees."
How I wish you would all add this short paragraph to your explanations
of air
quality standards somewhere for students to really understand the issue.
2. Please also let students understand that there is no air
quality limit
that is not "feasible" no matter how low it is set. Then
the
only consideration is money.
For example, if we have to use a two component urethane system in an
open shop,
I require the employer put our union workers in air-supplied respiratory
protection to keep below the 0.005 ppm TLV for the isocyanates.
Once the
employer has spent 4-5 large for the compressors and lines WHICH THEY
SHOULD
HAVE IN THE SHOP ANYWAY, it only cost about $100 more per employee than
air-purifying systems.
Done well, this system can keep the exposure to essentially zero.
And
better yet, the employer can install local exhaust ventilation such as a
walk-in sized spray booth.
The only balancing act, then is between money and workers health.
As the
old union song goes: Whose Side Are You On?
Monona
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