Document 2qwxez9XrzyxZOKN60o7zVzq5

T> CM CHEMICAL MANUFACTURERS ASSOCIATION August 4, 1988 To: Vinylidine Chloride Panel Be: NIOSH Cements on Adding VDC to OSHA "Z-Table" as a Carcinogen Enclosed are copies of the written and oral testimony given by NIOSH at the OSHA hearings on the "Z-Table" rulanaking. On pages 7-9 ani pages 13 - 16 of the written testimony, NIOSH suggests the addition of 53 chemicals, including VDC, as carcinogens and that PELS be established. Hie chemicals are covered by NIOSH Criteria Documents on Current Intelligence Bulletins. Mr. Dickson will be reviewing these documents and will advise the Panel an the appropriateness of ccnmenting. cc: B. Dickson Elizabeth J. Moran Manager, Vinylidine Chloride Panel ENVIRONMENTAL AF." SL 061910 >L tv n 'X 2003 7 202 887 MOO Tele* 89617 fCMA WSH) *s N(OSH staff presenting for Dr. Millar: Richard A. Lemen Director Division of Standards Development and Technology Transfer (DSDTT) Richard W. Niemeier Deputy Director Laurence D. Reed Acting Associate Director for Policy Development Theodore J. Meinhardt Assistant to the Director Office of the Director, DSDTT Office of the Director, DSDTT Office of the Director, DSDTT John J. Whalen Assistant Director Ralph D. Zumwalde Assistant Chief Office of the Director, DSDTT Document Development Branch, DSDTT Robert W. Mason Biologist Division of Biomedical and Behavioral Science Lawrence Fine Di rector Dawn G, Tha r r Chief Oivision of Surveillance, Hazard Evaluations and Field Studies (DSHEFS) Industrial Hygiene Sect ion,'Hazard Evaluations and Technical Assistance Branch, DSHEFS Paul E. Cap Ian Research Industrial Hygienist Engineering Control Technology Branch, Division of Physical Sciences and Engineering (DPSE) Donald D. DoIIberg Research Chemist Measurements Development Section, Measurements Research Support Branch, DPSE Nancy J. Bo 11inger Chief Chief, Certification Branch, Division of Safety Research Thomas Hodous Medical Officer Medical Section, Clinical Investigations Branch, Division of Respiratory Disease Studies 11 SL 061912 S I am Richard A. Lemen, Director of the Division of Standards Development and Technology Transfer (DSDTT) of the National Institute tor Occupational Safety and Health (NIOSH). With me today are senior staff from NIOSH research divisions, each of whom has expertise in various aspects of this rulemaking. Our purpose for appearing at this hearing is to support the Occupational Safety and Health Administration's (OSHA's) efforts to promulgate a new standard. NIOSH may make comments or recommendations in addition to those contained in this testimony, based upon other information presented during this hearing. I want to take this opportunity to commend OSHA for embarking upon this ruIemaking. effort. This comprehensive updating of the Z-Tables will directly influence the health of all American workers. NIOSH strongly supports OSHA in its desire to make the air contaminant standards consistent with the most current information. We agree that there is an urgent need to update the current air contaminant standards because they represent exposure limits based on data available prior to 1968. Current information on health effects indicates that more protective limits are required for many substances. Even though NIOSH will question some of the specific Permissible Exposure Limits (PELs) that have been proposed, NIOSH does not question the wisdom of this rulemaking. Although NIOSH will suggest that some proposed PELs are not optimal, NIOSH nevertheless advocates adoption of more protective PELs. Even if some PELs are less protective than NIOSH might prefer, the overall impact of this I-Table update represents a significant advance for worker `safety and health. On the other hand, it should be clearly understood by all that this rulemaking is an exceptional event made necessary by the passage of 20 years without significant reevaluation of the standards contained in the Z-Tables. This should in no way impede vigorous action in the future to promulgate comprehensive standards as specified under Section 6(b) of the Occupational Safety and Health Act. Instead this should serve as an impetus to proceed more swiftly and efficiently with comprehensive standards. NIOSH has transmitted to the Department of Labor 129 Criteria Documents and 50 Current Intelligence Bulletins (CIBs) (of these, one Criteria Document and one CIB were transmitted after this rulemaking was initiated). NIOSH Criteria Documents and CIBs are unparalleled in terms of the amount of information considered, the detail to which thct information is examined, the extent to which evaluations are subjected to external peer review prior to publication, and the care with which those evaluations are explained in the published recommendation. It is important that the record is clear on what a *J--RH Criteria Document represents in this regard. Criteria Documents are based on comprehensive reviews of the world's scientific literature. They routinely cite over 100 references and many cite several hundred. NIOSH does not rely upon information that 1- - SL 061913 cannot be made public. Critical evaluations of cited references with detailed discussions of their implications are included in Criteria Documents to provide the reader with an appreciation of their strengths, their weaknesses, and a clear description of how NIOSH interprets these publications. By this method, the reader has enough information to reach independent conclusions regarding these cited reports. Each draft Criteria Document is reviewed by experts representing affected industries, organized labor, and trade or professional organizations, and by scientists, physicians, and other health professionals with related experience in academia, government, or industry. The number of these external peer reviewers normally is greater than 10 and often exceeds twice that number. In addition to the invaluable contribution their comments make to the completed Criteria Document, OSHA receives, along with the completed Criteria Document, the full text of each reviewer's written comments accompanied by itemized annotations indicating how the draft was modified in response, or providing the rationale if the comment or recommendation was not adopted. Each Criteria Document contains an extensive summary in which the basis for the Recommended Exposure Limit (RED is carefully developed with clear and explicit citation of the data relied upon at all steps of the logical development. No other source of exposure limits approximates the comprehensiveness of these documents. NIOSH recommends that the chemical universe defined for the present rulemaking include all chemicals covered by NIOSH RELs. We recognize the practical necessity for OSHA to limit the universe of chemicals subject to this rulemaking, but as noted by OSHA in its preamble, there are relatively "few instances" of substances with a NIOSH REL but no threshold limit value (TLV). Including these substances would not significantly affect the "boundary on the number of substances to be evaluated," a concern expressed by OSHA in the notice for proposed rulemaking. NIOSH Table N5 (Appendix A) lists these 42 chemicals excluded up to now from the ZDable update. If these are not added to the current update, they should be targeted for priority rulemaking to begin immediately upon completion of the prese t effort. For a large number of the chemicals covered b> ;his rulemaking (277 to be exact), NIOSH concurs with the PEL being proposed by OSHA. These chemicals are listed in NIOSH Table N1 (Appendix A). For them, the available documentation appears to support the proposed exposure limits as adequate to protect workers from recognized health hazards. NIOSH questions the proposed PELS for the 31 chemicals listed in Table N2. They are: 1) Acrylic acid (HS 1009) 2) n-Butyl glycidyl ether (BGE) (HS 1052) 3) Camphor, synthetic (HS 1063) 4) Caprolactam vapor (HS 1065) -2- SL 061914 fs 5) Coal dust (<5% quartz) (HS 1096) 6) Coal dust (>5% quartz) (HS 1097) 7) Disulfoton - skin (HS 1152) 8) Ethyl bromide (HS 1163) 9) Ethyl ether (HS 1164) 10) Ethylene glycol vapor (HS 1169) 11) Fenthion - skin (HS 1175) 12) Fluorine (HS 1179) 13) Formamide (NIC - skin) (HS 1182) 14) Furfural - skin (HS 1183) 15) Heptane (n-Heptane) (HS 1194) 16) Hexane isomers (HS 1201) 17) 2-Hexanone (Methyl n-butyl ketone) (HS 1202) 18) Isopropoxyethanol (HS 1223) 19) Isopropyl acetate (HS 1224) 20) Isopropylamine (HS 1228) 21) Manganese tetroxide (HS 1238) 22) Mesityl oxide (HS 1243) 23) Octane (HS 1296) 24) Ozone (HS 1301) 25) Pentane (HS 1306) 26) 2-Pentanone (methyl propyl ketone) (HS 1307) 27) Silica--Amorphous (diatomaceous earth) (HS 1352) 28) m-Toluidine - skin (HS 1401) 29) Triethylamine (HS 1408) 30) Vinyl acetate (HS 1424) 31) Zirconium compounds, as* Zr (HS 1439) Examples of reasons for NIOSH's concern for the chemicals from NIOSH Table N2 are given for the following 2 substances. 1. Ethylene Glycol (EG) OSHA currently does not have a PEL and proposes a 50 ppm ceiling as the new PEL as recommended by the American Conference of Governmental Industrial Hygienists (ACGIH). In the NIOSH review of EG, we have found that positive rat and mouse teratogenicity for oral administration of EG has been reported by Lamb et al. [1985], Price et al. [1985], and Hardin et al. [1987], The summary statement by C. Price is germane to OSHA's consideration of PELs: "The lack of apparently serious maternal effects at the lowest dose which produced malformation in both species, as well as the severity and frequency of fetal defects at higher doses, suggest that EG may carry a selective risk to the embryo and should be considered a potential development hazard in situations where major EG exposure is likely to occur." -3- SL 061915 The interpretation of the human (volunteers) inhalation exposure study by Wills et al. [1974], as indicating a 50 ppm ceiling (125 mg/m3) TLV, is questioned. Review of the reported study indicates the most common complaint was irritation of the upper respiratory tract during the 30-day, 20-22 hours per day exposures at mean daily concentrations ranging from 3 to 67 mg/m^ (1.4-27 ppm) and the irritative phenomena became common when the concentration was raised to about 140 mg/m^ (56 ppm). Despite the significantly erratic exposure concentrations during the 30 days of "continuous" exposure, the reported irritation would indicate that a 50 ppm limit does not offer sufficient protection from respiratory irritation. The potential teratogenicity and the known respiratory irritation at the proposed level suggests that OSHA should reconsider their proposed PEL. * In addition, the OSHA Summary of Toxicology should be corrected to read for the Wills et al. study [page 21035 of the Federal Register notice, 2nd column, 19 lines from the top]: "In a human inhalation study, Wills and colleagues [1974] reported that volunteers exposed to the aerosol from 20 to 22 hours per day for 4 weeks, at mean daily concentrations between 3 and 67 mg/m3 (1.4-27 ppm) complained of throat irritation, and on occasion mild headache and lower back pain." 2. Ethyl Ether OSHA proposes to add a short-term exposure limit (STEL) to their current PEL of 400'ppm for Ethyl Ether. The current PEL is the same as the ACGIH TLV and the STEL of 500 ppm is also recommended by ACGIH. ACGIH set a TLV of 400 ppm time-weighted average (TWA) and a 500 ppm STEL based upon workers developing a tolerance to irritation at that level [ACGIH 1986]. Nelson et al. [1943] tested human subjects for a period of 3 to 5 minutes for sensory responses to ethyl ether and reported, "Complaints of nasal irritation began at 200 ppm. Three hundred was objectionable as a working atmosphere." It was further suggested that 100 ppm was the highest concentration which the majority of subjects estimated satisfactory for 8-hour exposure and 200 ppm was a level which produced nasal irritation in a majority of subjects. Nelson stated that the study reported is "not sufficient" to act as a basis for new limits. However, it would appear that a 400 ppm TWA may protect workers from systemic effects, but would not prevent irritation to some individuals. The concerns for the remaining 29 substances on NIOSH Table N2 have been submitted to the docket with NIGSH's written testimony. Some of the chemicals in the universe defined by the 1986 ACGIH TLV list have been excluded from this rulemaking by OSHA for a variety of reasons. NIOSH concurs with OSHA's determination on 127 substances -4- SL 061916 rn listed in NIOSH Table N3A (Appendix A) as not needing further revisions based on available data, but believes that those listed in NIOSH Table N3B (Appendix A) should be included in this rulemaking. NI OSH has identified 9 chemicals in NIOSH Table N3B which are of concern. They are: 1) Acetylene tetrabromide (HS None) 2) Chlorobenzene (HS None) 3) Chromium (II) compounds, as Cr (insoluble) (HS None) 4) Chromium (III) compounds, as Cr (insoluble) (HS None) 5) Cresol, all isomers - skin (HS None) 6) Manganese dust & compounds (HS None) 7) Molybdenum, as Mo (soluble compounds) (HS None) 8) Nitromethane (HS None) 9) Parathion - skin (HS None) CresoI will serve as an example of NlOSH's concern. The OSHA PEL and the ACGIH TLV [ACGIH 1986] for cresol both have identical exposure limits of 5 ppm (22 mg/m^), TWA, with a skin notation; therefore, this chemical is not being considered for revision. However, NIOSH has established an REL of 2.3 ppm (10 mg/m^), TWA, which should be considered in the revision of the OSHA standards. In 1952, ACGIH established a 5 ppm TWA based on an analogy with phenol [ACGIH 1986]. Ine toxicity of cresol compared to phenol was considered in two studies [Fairhall 1957; Hamilton et al. 1949]. It was believed the 5 ppm level would protect against irritation, and kidney and liver damage. N<0SH [1978] established an REL of 2.3 ppm (TWA). NIOSH reported that although the data indicates similarities in toxicity between cresol zr.t phenol when they are given by several routes of exposure, other evidence suggests that cresol is more toxic by inhalation [Uzhdavini et al. 1972]. The findings of Deichmann et al. [1963] agreed with Uzhdavini concerning the adverse effects of cresol below 20 mg/nm*. The NIOSH REL is more protective than the current OSHA PEL or TLV. NlOSH's concerns for the other 8 substances are attached to our written comments and are in the OSHA docket. ' `"ne!H Table N4 (Appendix A), NIOSH has identified 48 substances which OSHA is proposing to regulate as nuisance dusts. OSHA is proposing PELs for 47 substances (Table C10-1) that are currently reyuiated by OSHA's PEL for nuisance dust (15 mg/m3 for total dust and 5 mg/m^ for respirable dust). The proposed PELs are 5 mg/m^ for fibrous glass dust and 10 mg/m3 for the remaining 46 substances. The 10-mg/m^ PELs are based on the TLVs established for *-::c substances by ACGIH. Exposure to these substances is considered m adverse "nuisance" effects, including interference with vision, irritation of the upper respiratory tract and skin, and deposits of these substances in the eyes, ears, and nasal passages. Reactions of lung tissue to these substances are considered to be 'wversible when exposure ceases. -5- SL 061917 NIOSH has conducted a limited evaluation of the literature on the 48 substances in Table N4, and has concluded that the documentation cited by 05HA is inadequate to support the proposed PEL of 10 mg/m^ for many o he substances. Recent toxicologic and exposure data indicate that exposure to some of these substances may cause cancer or other serious adverse health effects. Adherence to the proposed PEL of 10 mg/m^ (total dust) would not prevent the toxicologic effects associated with many of these substances. NIOSH is therefore concerned that it is misleading to apply the term "nuisance dust" to such substances. NIOSH is also concerned that total dust exposure may be an inappropriate criterion for assessing the relationship between exposure and effect. The 48 substances considered here are present in many occupational environments within a respirable size range, and the respiratory system is therefore the most likely route of exposure. However, differences in particle morphology and size affect pulmonary defense mechanisms differently. Furthermore, solubility and pH must be determined to assess the effects of some substances on the mucous membranes. All of the characteristics of a substance need to be assessed when determining its potential toxicity. For substances that typically become airborne in the workplace as respirable particulates, a PEL based on the respirable fraction of the substance would be warrarited. Substances that exhibit a toxic effect upon contact with mucous membranes may more appropriately require exposure limits for both total and respirable particulates. NIOSH is further concerned that exposure to several of the`substances listed in Table C10-1 may involve concomitant exposure to free silica, which may cause silicosis or lung cancer. OSHA has proposed that the PEL for these substances be applied only when the quartz content is less than 1 percent. This criterion may understate the risk of airborne exposure to quartz, since the percentage of quartz is typically determined by analysis of the raw material or of the settled dust and not by analys nf airborne samples. Airborne samples should be collected and analy for free silica whenever workers are exposed to quartz or to any o' ;e substances associated with free silica. Exposure to free silica should be limited to concentrations below the NIOSH REL of 50 ug/m3. NiOSH is particularly concerned that toxicologic evidence demonstrates a relationship between exposure to certain substances listed in Table C10-1 and chronic respiratory disease, including cancer. Clear evidence of chronic respiratory disease has been observed in workers exposed to various types of mineral fibers [Walton 1987]. Enterline et al. [1987] reported a statistically significant risk of lung cancer in workers exposed to glass and mineral-wool fibers. This risk of cancer was also observed in animals [Stanton et al. 1980] when fibers with various physical and chemical characteristics were implanted in the pleurae of rats. The ability of these fibers to induce cancer was -6- SL r 'i discovered to be related to the length and diameter of the fibers and not to their chemical compositions. Rats dosed with fibrous glass, aluminum oxide, and silicon carbide exhibited a carcinogenic response similar to that of rats dosed with asbestos. The NIOSH evaluation of data on titanium dioxide indicates a risk of cancer from exposure. The incidence of tumors observed in animals exposed to titanium dioxide meets the OSHA criterion for potential occupational carcinogens (29 CFR 1990.103). Other data evaluated by NIOSH indicate that benomyl exposure may cause adverse reproductive effects and that magnesium oxide exposure may cause chronic respiratory disease. NIOSH has included pertinent literature on these substances as part of its submission, and OSHA should consider it in this rulemaking. Having selected the TIV list as the universe to be considered, OSHA frequently limits its consideration of health effects to those that the ACGIH considered when establishing the TIV. The full range of available toxicologic, epidemiologic, and exposure information should be considered for all chemicals in the universe selected. The need to do so is most evident for chemicals that NIOSH and others consider to be carcinogenic. For a large number of these chemicals, OSHA proposes to establish a PEL without identifying the chemical as a potential occupational carcinogen. In some cases, OSHA acknowledges without comment the conclusion by NIOSH or others that these chemicals are potential occupational carcinogens, but still does not so designate those chemicals, in some cases the limits proposed for adoption were based on carcinogenicity; in other cases they were based on'other acute or chronic health effects. Even if OSHA chooses not to accept NIOSH recommendations that occupational exposure to carcinogens should be restricted to the lowest feasible level, OSHA should designate these chemicals as potential occupational carcinogens because these chemicals meet the criteria for carcinogenicity as established by OSHA [29 CFR 1990.103]. Chemicals that should be designated as potential occupational carcinogens are listed in NIOSH Tables N6A and N6B (Appendix A) and have been submitted to the OSHA docket with our written testimony. On Table N6A, NIOSH has identified 39 substances which have proposed PELs that NIOSH can agree with, but for which a carcinogen designation should be added to the PEL. The chemicals are; 1) Acrylamide - skin (HS 1008) 2) Aldrin - skin (HS None) 3) Amitrole (HS 1020) 4) Aniline & homologues - skin (HS 1025) 5) Anisidine (o~, p-isomers) - skin (HS None) 6) Captafo! - skin (HS 1066) 7) Captan (HS 1067) 8) Carbon tetrachloride - skin (HS 1073) 9) Chlordane - skin (HS None) 10) Chloroform (HS 1086) -7- SL 061919 11) Dichloroacetylene (HS 1123) 12) DichloroethyI ether - skin (HS 1127) 13) Dichloropropene - skin_(HS 1129) 14) Dieldrin - skin (HS None) 15) Diglycidyl ether (OGE) (HS 1139) 16) Dimethyl sulfate - skin (HS 1142) 17) Dinitrotoluene - skin (HS None) 18) Dioxane - skin (HS 1145) / 19) Di-sec-octyl phthalate (HS 1116)'/ 20) Ethylene dichloride (HS 1168) 21) Heptachlor - skin (HS None) 22) Hexachlorobutadiene - skin (HS 1195) 23) Hexachloroethane - skin (HS 1197) 24) Hexamethyl phosphoramide (HS None) 25) Methyl iodide - skin (HS 1259) 26) Nickel carbonyl (as Ni) (HS 1284) 27) Propylene imine - skin (HS None) 28) Silica - crystalline (cristobalite) (HS 1354) 29) Silica - crystalline (tridymite) (HS 1356) 30) 1,1,2,2-Tetrachloroethane - skin (HS 1385) 31) To Iuene-2,4-diisocyanate (TDI) (HS 1398) 32) o-Toluidine - skin (HS 1399) 33) 1,1,2-Trichloroethane (HS None) 34) Trichloroethylene (HS 1406) 35) 1,2,3-Trichloropropane - skin (HS 1407) 36) Uranium (insoluble compounds, as U) (HS 1418) 37) Uranium (soluble compounds, as U) (HS 1419) 38) Vinyl cyclohexene dioxide (HS 1426) 39) Wood dust (hard wood) (HS 1430A) There are 53 chemicals on NIOSH Table N6B that not only should be designated as carcinogens, but for which there remains a substantial level of risk at the proposed PEL. The substances are: 1) Acetaldehyde (HS 1001) 2) Arsine (HS None) 3) Asphalt (petroleum) fumes (HS 1028) 4) Benzo(a)pyrene (HS None) 5) Beryllium & compounds, as Be (HS 1033) 6) tert-8utyl chromate, as Cr03 - skin (HS None) 7) Carbon black (HS None) 8) Chlorinated camphene - skin (HS 1078) 9) ChIorodiphenyl (42% chlorine) - skin (HS None) 10) Chlorodiphenyl (54% chlorine) - skin (HS None) 11) Chromic acid and chromates (HS 1092) 12) Chromite ore processing (chromates), as Cr (HS None) 13) Chromium (VI) compounds, Cr (water soluble) (HS None) 14) Chromium (VI) compounds, Cr (certain water insoluble) (HS None) 15) Chromyl chloride (HS 1094) 16) Chrysene (HS None) -8- SL 061920 fX 17) Coal tar pitch volatiles, as benzene solubles (HS None) 18) DOT (Dichlorodiphenyl-trichloroe>tfane) (HS 1113) 19) p-Oichlorobenzene (HS 1125) 20) Dimethyl carbamoyl chloride (HS None) 21) 1,1-DimethyIhydrazine - skin (HS None) 22) Epichlorohydrin - skin (HS 1158) 23) Ethyl acrylate - skin (HS 1161) 24) Ethyl chloride (HS None) 25) Gasoline (HS 1185) 26) Hydrazine - skin (HS 1205) 27) Lead chromate (as Cr) (HS None) 28) Methyl bromide - skin (HS 1253) 29) Methyl chloride (HS 1254) 30) Methyl hydrazine - skin (HS None) 31) 4,4'Methylene bis(2-chloroaniIine) - skin (HS 1273) 32) Nickel (soluble [or inorganic] compounds as Ni) (HS 1283) 33) Nickel sulfide roasting, fume & dust (as Ni) (HS None) 34) p-Nitrochlorobenzene (HS 1288) 35) 2-Nitropropane (HS 1291) 36) Perchloroethylene (HS 1308) 37) N-PhenyI-beta-naphthylamine (HS None) 38) Phenyl glycidyl ether (PGE) (HS 1315) 39) PhenyIhydrazine - skin (HS 1317) 40) Propane sultone (HS None) 41) Propylene dichloride (HS 1341) 42) Propylene oxide (HS 1344) 43) Rosin core solder pyrolysis products, as formaldehyde (HS 1350) 44) Silica--Crystalline (quartz) (HS 1355) 45) Silica--Crystalline (tripoli) (HS 1357) 46) Silica--Crystalline (fused) (HS 1358) 47) o-Tolidine -skin (HS None) 48) p-Toluidine - skin (HS 1400) 49) Vinyl bromide (HS 1425) JQ1 Vinvl irlene chloride (HS 1428^> 51) Welding fumes (HS 1430) 52) Wood Dust (soft wood) (HS 1430b) 53) Zinc chromate, as Cr (HS 1436) Some chemicals on NIOSH Tables N6A and N6B have been excluded from this rulemaking by OSHA as is evident from their lack of a HS number. However, NIOSH concludes that OSHA should include these chemicals in this rulemaking. On NIOSH Table N7, NIOSH has identified 15 substances for which OSHA intends to adopt a TWA instead of the recommended NIOSH Ceiling Value. NIOSH recommends that OSHA adopt the NIOSH Ceiling Values to provide the most appropriate degree of health protection. These substances are: -9- SL 06l92i Butyl mercaptan (HS 1054) Benzyl chloride (HS None) Cyanides (as CN) - skin (potassium cyanide) (HS None) Cyanides (as CN) - skin (sodium cyanide) (HS None) Hydrogen sulfide (HS 1209) Hydroquinone (HS None) Isopropyl glycidyl ether (IGE) (HS 1227) Methyl chloroform (HS 1255) Methyl mercaptan (HS 1263) Petroleum distillates (naphtha; rubber solvent) (HS 1312) Phenol - skin (HS None) Phenyl mercaptan (HS 1316) Phosgene (HS None) Vanadium (as V205) - respirable dust fume (HS 1421) Vanadium (as V205) - fume (HS 1422) turning now to the specific questions posed in the NPRM: 1. Are substances incIuded which shouId be excIuded rulemaking? om this No. On the contrary, substances were excluded which should have been included. Immediately upon completion of this rulemaking, OSHA should take action to establish PELs for all substances that are excluded from this rulemaking despite the existence of a formal NIOSH recommendation to OSHA. As a first step, OSHA should initiate consolidated rulemaking similar to the present Z-Table update to adopt all NIOSH RELs pending chemical-specific Section 6(b) rulemaking to establish comprehensive standards. 2. Is additional health and feasibility documentation available relative to the proposed PELs beyond that described in the preamble? Yes. OSHA has frequently limited itself to the documentation used by the ACGIH in support of TLVs. Whenever available, NIOSH Criteria Documents, Current Intel Iigence Builetins, and Alerts should be considered by OSHA in its final rulemaking. For many of the chemicals, substantial databases are available from other governments (e.g., Germany, the United Kingdom, Sweden), as well from organizations such as the International Labor Organization, the American Industrial Hygiene Association, the Nordic Expert Group for Documentation of Occupational Exposure Limits, and the National Library of Medicine. A large number of National Cancer Institute (NCI), National Toxicology Program (NTP), and International Research on Cancer (IARC) monographs on chronic bioassay reports are available that provide extensive information on acute and chronic systemic toxicity in addition to data on potential carcinogenicity. -10- f SL 061922  As part of this response, NIOSH is providing a chemicaI-by-chemicaI discussion with citations of the most pertinent supporting data that could be identified within the time limitations. For chemicals included in the PEL update, copies have been submitted to the docket of all pertinent NIOSH Health Hazard Evaluations (HHEs), as well as all citations for toxicity contained in the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS). These data are collected as mandated by Section 20(a)(6) of the Occupational Safety and Health Act of 1970 (PL 91-596). These data are publicly available and will assist OSHA in fulfilling its obligation under the Occupational Safety and Health Act to consider "the latest available scientific data in the field." NIOSH has not attempted to provide OSHA with the other elements the Act requires OSHA to consider, namely, "...the feasibility of the standards, and experience gained under this and other health and safety laws." The HHE reports will provide some idea of the exposures found during requested NIOSH evaluations in industry. NIOSH is continuing to develop information and will provide to OSHA other relevant data on exposure concentrations found in industry in our post-hearing cooments. These data should assist OSHA in determining feasi bility. In addition to these publicly available sources of information, OSHA should ask major employers throughout the country to provide listings of all of their own internal exposure limits along with their documentation of those limits. In many industries these may be more restrictive than existing OSHA PELs, and this should be an excellent source of information on feasibility of various limits. Because many of the proposed PELs are derived from TLVs, OSHA should obtain from the ACGIH all unpublished data that contributed to the establishment of those TLVs. OSHA should follow up on these unpublished data to make the record as complete as possible. Dimethyl Formamide (DMF), a compound from NIOSH Table N3A, is of particular interest to both NIOSH and OSHA because of recent published information concerning testicular cancer and liver disease. NIOSH will provide to OSHA a summary of these data presently in preparation. 3. Are substances included in this rulemaking used in industries other than those described in the preamble? and 4. Are substances included in this rulemaking used for purposes other than those described in the preamble? -11- SL 061923 NiOSH has previously supplied to OSHA, at their request, a printout of the complete NIOSHTIC data base file on approximately 260 chemicals to aid in the identification of additional industries using the chemicals in this rulemaking. NIOSH is continuing to search its data base files (National Occupational Hazard Survey [NOHS]) for additional information which will be provided during this rulemaking process. 5. Do alternative unpublished exposure guidelines exist, such as those used in private workplaces, which nay be suitable for general usage? NIOSH is aware of the existence of internal exposure guide Iines in a number of private workplaces. NIOSH surveyors, in assessing ethylene oxide exposure, often found internal workplace controls in the 1 to 2 ppm range when the OSHA PEL was 10 ppm. Some of the proposals for change by ACGIH incorporate workplace exposure limits being used in industry at the time of the change. Nickel carbonyl is an example. This documentation relates that a nickel refinery in Sudbury, Canada, begins treating their workers for nickel carbonyl poisoning when their blood level of nickel reaches 150 micrograms/Iiter. It is further noted that the factory sounds an alarm when air concentrations read 10 ppb and an evacuation alarm sounds at 80 ppb. In this case the TLV is 5 times the level thought to be safe. There are existing guidelines on exposure to radioactive materials published by the International Commission on Radiation Protection (ICRP) and by the National Commission on Radiation Protection, which are applicable to radioactive substances, specifically, soluble and insoluble uranium in this rulemaking. Before considering unpublished data, OSHA should update the published information on.which it is relying for this proposed rule. A cursory review indicates that 72% of the references cited by OSHA were published prior to 1980 and 35% prior to 1969. The latter is the publication date for the current Z-1 table. NIOSH has submitted a complete set of references for each of the substances under consideration from its RTECS data base. 6. Is there information regarding laboratory analytical procedures which may be used in lieu of those suggested by OSHA (see Appendix A) to determine exposure to air contaminants? NIOSH has transmitted to OSHA all of its applicable analytical procedures. NIOSH would caution OSHA that, in the ''Sampling and Analytical Methods" table, several existing NIOSH analytical methods have been extended to compounds for which the suggested method has not been verified. Some of these compounds have -12- *1 SL 061924 markedly different chemical properties than the compound(s) for which the method was developed. These methods will require validation before use: Method Validated for Extension orooosed bv OSHA HS # N1 OSH 1003 NIOSH S43 NIOSH 1400 NIOSH 1400 NIOSH 1603 NIOSH 1003 NiOSH 1020 NIOSH 1020 NIOSH 1003 NIOSH 1003 NIOSH 1500 NIOSH 1500 NIOSH 5021 NIOSH 2002 NIOSH S264 NIOSH 1500 NIOSH 2002 NIOSH 2002 halogenated H/C methyl methacrylate i sopropano1 isopropano1 acetic acid halogenated H/C 1,1,2-trichloro- 1,2,2-trifluoroethane 1,1,2-trichloro1,2,2-trifluoroethane halogenated hydrocarbons halogenated hydrocarbons hydrocarbons hydrocarbons terphenyIs aromatic amines ethyl si 1icate hydrocarbons aromatic amines aromatic amines 1,3-dich1o rop ropene 2-hydroxy Ip ropy 1 acrylate propargyl alcohol isooctyl alcohol trichloroacetic acid dichloroacetylene ch1o rodifluoromethane chloropentafluoroethane o-chlorostyrene o-chlorotoluene cyclopentane hexane isomers hydrogenated terphenyIs N-isop ropy Iani1ine methyl silicate nonane p-toluidine m-toluidine 1129 1211 1335 1220 1404 1123 1085 1087 1089 1090 1111 1201 1210 1229 1266 1293 1400 1401 The foil owing are corrections to the NIOSH Analytical Methods for PEL Update Table (pp. 21308-21312 of the Federal Register). No, Analyte Correct NIOSH Validated Method 4 acetone 17 ammonia 20 ammonium sulfamate 63 carbon Dioxide 190 hexach1o rocyc1 open tadiene 304 petroleum disti1lates (naphtha) 1,2,3-trichloropropane NIOSH 1300 Add NIOSH S347 NIOSH S348 NIOSH S249 NIOSH 2518 NIOSH 1550 NIOSH 1003 7. Are the proposed exposure limits for each substance appropriate? NIOSH has addressed comments on each exposure limit it believes to be inappropriate, and has submitted these comments with supporting data to the docket as specified by OSHA in part VIII of the proposed rule. -13- SL 061925 8. Is additional information available for those substances for which ACGIH proposed a higher TLV which might affect OSHA's decision that such a change was not justified? This rulemaking is not an appropriate proceeding for raising any permissible exposure limit. The decision to raise an occupational exposure limit should only be made through a full 6(b) rulemaking procedure with adequate time for all concerned parties to respond. NIOSH has examined all of the available additional scientific information on substances for which the ACGIH TLV is higher and has commented where appropriate. The only substance included on Table C16-1 (Federal Register. p. 21211) that OSHA proposes to raise is Fluorine (HS 1179), and NIOSH has submitted detailed comments on this chemical which demonstrate that OSHA was not justified in raising the proposed ''EL. Additionally, OSHA inadvertently .ted (on p. 21029 of the Federal Register) that the currer )SHA PEL for Synthetic Camphor (HS 1063) is 2 ppm rather than 2 (0.3 ppm). Because of this error, OSHA proposed to adopt the ACGIH TLV and STEL, i.e. 2 and 3 ppm, respectively, which is approximately 7 times higher than the current PEL. 9. Should the implementation dates for some substances be delayed because of sampling/analytical limitations or short-term feasibility impact considerations? Delaying the implementation date would not be technology forcing with regard to reducing occupational exposures. However, it is extremely important to note that for many substances listed in the update, there are no sampling and analytical methods available or the method given has not been validated by either NIOSH or OSHA. Also, many of the proposed methods are in-house OSHA methods which are not available to NIOSH or the general public for evaluation. Finally, there are methods whose Limit of Quantitation cannot support the proposed PEL or STEL. These problems are critical and must be corrected for proper enforcement of the regulation. Therefore, it is important that NIOSH and OSHA work together on a method development scheme that will allow the appropriate validated methods to be developed in a prioritized fashion within the implementation of the regulation. Also, it is imperative that OSHA set a high priority for promulgating followup regulations that deal with these sampling and analytical issues. f1 -14- SL 061926 10. Is there additional information relative to the OSHA plans to adopt some recommended 10-hour TWA REL's as an 8-hour PEL? A NlOSH REL "... determined as a time-weighted average (TWA) exposure for up to a 10-hour work day, 40-hour work week" first appeared in the 1973 Inorganic Arsenic Criteria Document. That document was developed during the energy crisis of the early 1970's, when many employers began using 10-hour work days as an energy conservation measure. Consideration was given to recommending a mathematical adjustment of TWA RELs based on a constant limitation of the Concentration x Time for 8-hour and longer work days. For example, an 8-hour TWA of 100 ppm (100 ppm x 8 hr * 800 ppm hr) would convert to 80 ppm for a 10-hour day (800 ppm hr/10 hr * 80 ppm hr). The conclusion at the time was that, so long as the work schedule did not exceed 10 hours per day or 40 hours per week, there was not sufficient precision in the selection of exposure limits to justify the precision implied by that mathematical adjustment. Therefore, the same TWA REL was intended to be applied to 8-hour and 10-hour work days in a 40-hour work week. The action proposed by OSHA in this rulemaking relative to these RELs is consistent with that original intent. A mathematical conversion in the opposite direction, i.e., converting a 10-hour TWA of 100 ppm (1000 ppm hr) to an 8-hour TWA of 125 ppm (1000 ppm hr), would be contrary to the original intent and would be opposed by NlOSH. 11. Does the most current scientific information generally support acceptance of the hypothesis that ail C-S-8-Alkanes are not equally toxic because a metabolite of n-Hexane exhibits unique neurotoxic properties? It is generally accepted that the metabolite that is responsible for the neurotoxic effects of n-hexane is 2,5-hexanedione (2,5-tffi), a gamma diketone. This compound is also a metabolite of methyl-n-butyI ketone (MnSK), but is not known to be a metabolite of other alkanes in the C-5 to C-8 group. 2,5-HD produces axonal degeneration (so-called "central peripheral distal axonopathy") characterized by a breakdown of neurofilaments and their accumulation distal to Ranvier nodes in the neuron. The observable symptomatology is, in sequence, limb weakness, severe paralysis, and muscle degeneration. The observation of similar neuropathies after exposures to MnSK or n-hexane and the discovery of their common metabolite, 2,5-HD, suggested the specific hypothesis that it is the gamma spacing of the diketone in the molecule that is the necessary and sufficient characteristic for producing this type of neuropathy. It would be correct to state that 2,5-HD is the principal neurotoxic metabolite of n-hexane and Mn8k. It should also be recognized that any gamma diketone or any compound that may be metabolized to a gamma diketone (e.g., 5-nonanone metabolized to -15- SL 061927 2,5-nonanedione) may bo neurotoxic. It would be incorrect to conclude that the ne oxic properties ascribed to n-hexane are unique to this compc. Other alkanes or related chemicals that are ultimately metabolized to a gamma diketone may have similar toxicity. 12. OSHA has proposed to use exposure limits from two well-established sets of guidelines as a source of values to update the PELs. Is information available about alternative sources which OSHA might consider for this purpose? In its preamble to this proposed rulemaking, OSHA referred to 9 alternative sources: International Labor Organization World Health Organization European Economic Community United Kingdom Occupational Exposure Limits West German Maximum Allowable Concentrations Swedish Allowable Workplace Air Concentrations Japanese Permissible Exposure Limits American National Standards Institute American Industrial Hygiene Association Another possibility is the Nordic Expert Group for Documentation of Occupational Exposure Limits. t NIOSH believes all of these should be considered as equal or superior to the ACGIH TLV list in terms of the the criteria listed by OSHA. No single source should be expected to stand alone as a comprehensive list of candidates for regulation. OSHA should construct its own comprehensive list by drawing information from alI avaitable sources. No single list is current in its entirety. Although the ACGIH TLV list is republished annually, it is a mistake to assume that every TLV is reconsidered annually. The annual republishing is only a mechanism whereby those TLVs that have been revised can be disseminated. The ACGIH does not claim to reevaluate every TLV on a regular schedule. Economic and technical feasibility may be considered by the ACGIH in developing TLVs, but those considerations, if any, are not defined in the documentation of TLVs. Feasibility information for PELs derived from agencies listed above would be comparable, in most cases, to that provided by the ACGIH in support of TLVs. f1 -16- SL 061928 * OSHA should consider the availability and quality of documentation on a sub$tance-by-substance basis and use all available documentation, rather than select an exclusive list of substances simply because that list consistently has some documentation. The fact that the alternative sources listed above do not originate in the U.S. should not disqualify them from consideration of applicability. They should be judged against what is required to protect workers from the known toxicity of each substance regulated. Only after determining the level of control necessary to ensure a safe and healthy workplace should other factors be considered. Because they are limits that other officials have judged necessary to protect worker safety and health, NIOSH believes that OSHA should at least consider limits from all of the sources listed above. 13. OSHA has out Iined its criteria for identifying special situations. Are alternative criteria available which night be used in lieu of these, or In addition to then? OSHA has identified five circumstances that it considers special situations: Situations one and two involve a comparison of the ACGIH TLVs to four alternate data bases--the United Kingdom 1987 Occupational Exposure Limits, the West German 1985 Maximum Allowable Concentrations, the Japanese 1983 Permissible Exposure*Limits, and the Swedish 1984 Allowable Workplace Air Concentrations. OSHA Tables 1-F-C and 1-F-D, that are based on these comparisons, are not accurate. NIOSH has reviewed the pertinent data on selected substances on Tables 1-F-C and 1-F-D and has submitted comments on the appropriateness of the limits proposed. Situation three involves the substances where the current TLV exceeds the existing PEL. NIOSH has addressed this issue in the response to question 8. Situation four involves the circumstances where the available '"'alytical methods are not adequate to measure the substance at the air concentration proposed. NIOSH has addressed this situation in the answer to question 9. In the fifth situation where recent information suggests that neither the TLV nor the REL is appropriate, NIOSH finds it difficult to identify the exact substances to which OSHA is referring. NIOSH has commented on those substances which, based on the best available scientific information, meet OSHA's occupational carcinogen definition. On other substances where recent information indicates that neither the TLV nor the REL is -17- SL 061929 low enough to be adequately protective, OSHA should adopt the lower of the available limits and immediately schedule the substance for expedited rulemak; 3. 14. OSHA has outlined three alternate procedures for dealing with substances requiring special attention. Are additional approaches available which eight be used in lieu of these, or in addition to them? NIOSH would support OSHA in its decision to adopt either the level proposed or such other level as the evidence presented to the record indicates as proper for these substances, and identify them as possibly requiring followup rulemaking. NIOSH has endeavored to provide OSHA with the required data for selecting a proper limit for selected substances on Tables l-F-C and l-F-D. NIOSH concurs with OSHA that it is in the best interest of the worker to promptly provide such inerted health protection as is indicated by the evidence in the ret i. 15. OSHA has performed feasibility analy 4 for the following substances, based on limited available information: Acetonitrile, Carbon disulfide, Carbon monoxide, Carbon tetrachloride, Chloroform, Ethylene dichloride, Ethylene glycol dinitrate, Fibrous glass dust, Hydrogen cyanide, (sophorone diisocyanate, Nitrogen dioxide, Nitroglycerin, Trichloroethylene. Is further information available which might be used to supplement the present findings regarding the feasibility of achieving these levels In the workplaces? From NIOSH research data, we are including a detailed engineering feasibility study (Appendix B) for those listed in the question, as well as for the following chemicals: Acetone, Chlorine, Styrene, and Sulfur dioxide. 16. OSHA has made a preliminary assessment of the proposed rulemakings' impact on large and small establishments. The Act requires OSHA to determine whether a regulation will have a significant impact on a substantial number of small entities, pursuant to the Regulatory Flexibility Act of 1960, 5 U.S.C. 601 et seq. Is there additional information regarding implementation of this rule for small businesses and entities which OSHA should consider? NIOSH has no comment. 17. OSHA has proposed PEL'S for some substances where the basis of this proposal also includes a carcinogenicity designation (e.g., TLV with an A1 or A2 designation; REL with a Ca designation). Should OSHA include a similar carcinogen designation in the Z-4 Table in this rulemaking? -18- SL 061930 t Yes. For both the TLVs and the RELs, the carcinogen designation is an inseparable part of the recommendation. OSHA should include carcinogen designations for all chemicals that meet the OSHA definition of "potential occupational carcinogen" (29 CFR 1990.103). 18. OSHA has preliminarily decided that for substances where the ACGIH TLV is a TWA and the NIOSH REL is a Ceiling Value which is the same or one half of the TWA, OSHA will propose that the TWA be adopted as the PEL. Should this approach be modified in the final rulemaking? What approach should be used when the converse of this situation (TLV, Ceiling REL, TWA) exists? NIOSH would suggest that this question fails to recognize the essential differences between a time weighted average (TWA) and a Ceiling Value. A TWA is appropriate as a limit when the toxic effect of the substance is directly related to the total dose received, in a daily exposure. Ceiling values are intended to minimize toxic effects related to the peak exposure. Ceiling values are necessary when there are immediate acute responses to an air contaminant independent of the total daily dose or when chronic effects are dose-rate response related. In conjunction with a TWA, ceiling values are also used to minimize the total daily dose when there is intermittent occupational exposure, e.g., ethylene oxide. The simple numerical relationship that OSHA has proposed is not a scientifically sound basis for selecting between a TWA and a ceiling value. An analysis of the data supporting the proposed limit must be conducted on a case-by-case basis to discern which I imi t is appropriate. NIOSH has submitted specific comments on a substance-by-substance basis in this category to assist OSHA in selecting the appropriate limit. These substances are listed in the NIOSH Table N7 of the NIOSH comments. 19. OSHA preliminarily plans to adopt a phased start-up schedule. This would include an initial start-up requirement permitting the use of alternate control methods for revised PEL'S, followed at a later date by the required use of control methods fully consistent with the methods of compliance priorities in effect at that time. OSHA will shortly be requesting comments on the hierarchy of controls. An alternate approach is to set a compliance date for engineering controls based on final determinations of that rulemaking. OSHA solicits comments on those approaches and suggestions regarding appropriate times for the two proposed start-up dates. -19- SL 061931 NIOSH believes that work practices and engineering controls such as substitution, isolation, and ventilation should be used to control occupational exposures to the fullest extent feasible. NIOSH believes that personal protective equipment should be worn only when engineering controls are not feasible, such as during maintenance procedures. NIOSH recommends that OSHA allow industry 6 months to come into compliance by any combination of control methods, and 2 years for compliance by the NIOSH recommended hierarchy of control methods [NIOSH 1983], OSHA currently is recommending that industry be allowed 4 years to come into compliance by OSHA's hierarchy of control methods. Furthermore, NIOSH recommends that OSHA require staged implementation over the 2-year period of conversion to the hierarchy. This latter requirement would be technology forcing and it would minimize the occurrence of last minute requests to OSHA for variances to meet the conversion requirement. 20. OSHA requests comment on whether the establishment of margins of safety below lowest observed or no effect levels is consistent with the concept of "significant risk," and on whether the specific margins of safety proposed for specific chemicals are appropriate. Margins of safety and safety factors are attempts to adjust for uncertainty in available data and knowledge. The use of a margin of safety or a safety factor approach to identify exposure limits does not estimate the human risk associated with those proposed exposure limits. Therefore, such an approach cannot be considered to provide protection against or to reduce "significant risk" (either in a general conceptual sense or in the sense of any specific judicial precedent). Nonetheless, NIOSH recognizes that a thorough case-by-case evaluation for all major industrial agents may not be possible for a variety of reasons, and the use of a margin of safety or a safety factor approach to identify exposure limits for those chemicals provide a pragmatic method to develop standards. The exception to this statement is that NIOSH does not believe such an approach should be used to identify an exposure limit for an adverse health effect that results from non-threshold processes (e.g., cancer). In developing its recommendations to OSHA, NIOSH conducts thorough evaluations of all research data, estimated human risks associated with specific exposures, the sensitivity of measurement and analytic methods, alternative technologies,, technological feasibility of various exposure levels, background or ambient exposure levels, methods of worker protection, and many other factors pertinent to specific exposure agents or environments. NIOSH knows of no other method to develop reliable exposure limit standards that is consistent with NIOSH's -20- SL 061932 t} 2. Are there episodes of identifiable respiratory i1Iness? 3. Does the effect resul t in an incapacitating illIness? 4. Is there permanent respiratory injury? 3. Is there progressive respiratory dysfunction? Particularly on the job, sensory irritation is clearly relevant to point 1. Mucous membrane irritation is associated with respiratory illnesses, depending on the composition of specific exposure and on the dose, duration, and frequency of exposure. No universally applicable conclusion can be drawn at this time regarding the association between irritative symptoms and permanent injury of dysfunction. Where certain individuals show no measurable impairment after an exposure, even when experiencing irritative symptoms, others may develop identifiable dysfunction. Aside from the effects of irritation, mucous membrane exposure may result in absorption of a substance, with resultant systemic toxicity. An inflamed mucous membrane may be an even more effective route of absorption, either for the irritant or for other substances. Furthermore, injury to bronchopulmonary membranes can impair removal of particulates from the respiratory system. 22, The question also arises of whether odorants present material impairment of health. That issue also might arise in the context of other substances. Based on the evidence in the final record concerning this issue, OSHA will determine if the criteria detailed in section IV-C-16 have been met, and take appropriate action. OSHA requests comment on this issue. Odors emitted by industrial chemicals often play an important role in occupational safety and health. When odors can be detected before health effects occur, they may provide early warning of exposure. A number of chemicals have strong odors at concentrations which are otherwise minimally toxic. These odors may cause undue health concerns among exposed workers or may wieate safety hazards by distracting workers from their tasks. Strong odors in the workplace may also mask the presence of other, more toxic substances. Strong odors can produce irritation and/or nausea at high concentrations, although these effects may be reversible following cessation of exposure. Olfactory fatigue often occurs and should be considered a functional impairment that can result in increased worker exposure. Olfactory fatigue can reduce the wearer's ability to sense inadequate respirator performance of air-purifying respirators. -22- SL 061933 responsibility from the OSHAct to assure as far as possible, every working man and woman in the Nation, safe and healthful working conditions. Since the use of a margin of safety or a safety factor approach does not address essential issues required to develop a reliable exposure limit, including evaluation of "significant risk," NIOSH recommends that any standards developed by the use of a margin of safety or a safety factor approach be considered interim standards. NIOSH recommends that standards based on a margin of safety or a safety factor approach, as well as standards derived from a case-by-case evaluation, be periodically reviewed to determine what new information is avaitable. NIOSH is not recommending specific margins of safety or safety factors on any chemical. 21. OSHA has identified sensory irritation, which causes rhinitis, cough, sputum production, chest pain, wheezing and dyspnea as material impairment of health. OSHA invites comments on this understanding. The recognition of sensory irritation as potentially being "material impairment of health" is consistent with the current scientific consensus related to health effects of environmental agents. Mucous membrane irritants can cause increased blink frequency and tearing; nasal discharge, congestion, and sneezing; and cough, sputum production, chest discomfort, wheezing, chest tightness, and dyspnea. Work environments often require levels of physical and mental performance considerably greater than those encountered in daily living. Even in the absence of any permanent impairment, the symptoms listed can interfere with job performance and safety. Mucous membrane irritation can result in inflamnation, which may lead to increased susceptibility to nonspecific irritants and infectious agents. For example, experimental ozone exposure in humans results in increased airway reactivity. Also, studies of exposure to environmental tobacco smoke have shown irritative symptoms and evidence of increased frequency of respiratory tract illnesses in young children and decreased pulmonary function in adults. The American Thoracic Society has identified several points relevant to the issue of respiratory tract irritation. 1. Does the effect interfere with normal activity of the individual? 21- ( SL 061934 T ) 23. Is there exposure information available which can be supplied which will refine OSHA's estimates of employee exposures and over exposures to the substances being regulated? NIOSH is submitting for the current rulemaking all relevant Health Hazard Evaluation Reports (HHEs) to the docket. Appendix C is a comprehensive listing of HHEs being submitted. We also have previously submitted to OSHA a copy of data tapes from the National Occupational Health Survey (NOHS). NIOSH anticipates submitting to OSHA a comprehensive listing of pertinent NIOSH exposure information in our post-hearing comments. 24. Is there information available which can be supplied to improve or supplement the engineering controls identified as necessary in order to reduce exposure levels? Is there additional cost data which can be supplied to refine the annual costs associated with these controls? In addition to the material on engineering feasibility provided to OSHA relating to question 15, NIOSH is continuing to evaluate general engineering feasibility data for these substances in this rulemaking that meet OSHA's definition of a potential occupational carcinogen (29 CFR 1990). 25. Under what conditions, involving which industrial processes, will respirators be needed during the start up period, for maintenance operations, or where other controls are infeasible in order to protect employees at the proposed exposure levels? Are respirators currently being used under the conditions identified, or would they need to be purchased? Please describe the type of respirator currently in use or needed. NIOSH concurs with OSHA's assessment in the Non-Regulatory Alternative Section that personal protective equipment should only be used "where it fs impractical to apply engineering or work practice controls, or where these applications will not consistently reduce employee exposures below the proposed PEL'S." In these instances, NIOSH recommends that the NIOSH Respirator Decision Logic (Appendix D) be used to select the appropriate respirator. NIOSH has little quantitative information on which respirators are currently being used under the conditions specified by OSHA. A NIOSH contractor's report ("Preliminary Survey of Existing Data and Economic Overview of Respirator Industry," Granville Corporation, March 10, 1982) is submitted to the docket as Appendix E and provides limited data on the numbers and types of respirators sold in the United States. This report used respirator manufacturers' data on respirator sales in 1980 and published data on workers [i.e., Economic Report of the -23- SL 061935 President. (U.S.G.P.O., Washington, 1981)] to make some estimates on the number of certified respirators being worn by workers in the U.S. The Granville report estimates that 19.1% of mining, manufacturing, and construction workers wore or had access to certified respirators in 1980. In addition, it was estimated that over 20 million manufacturing workers and almost 4.5 million construction workers, and more than 1 million miners used certified respirators* The Granville report also indicated that SCBAs, "disposables," and particulate and chemical cartridge respirators have "large and roughly equal market shares (ranging from 25 to 30%) in terms of total dollar sales" (Granville Report, p. 40). 26. As a result of simultaneously regulating many substances, what cost savings will be realized in purchasing new engineering controls? Are alternate engineering controls available to achieve the lower permissible exposure limits being proposed? NIOSH has no comment with regard to the costs of purchasing new engineering controls. Alternate engineering control methods are discussed in our responses to questions 15 and 19. 27. What is the current state of technology control and financing in fiYms which would need to comply with reduced exposure limits to wood dust? In addition to the information provided on the individdal chemical comments for Wood Oust (H.S. 1430A and 14306), several innovative designs and devices have been developed to control wood dust in sawing, cutting, sanding and shaping. These published NIOSH references (Huebener DJ (1987], Oust controls for a wood shaper. Appl Ind Hyg 2(4):164-169; and Hampl V and Johnston DE [1985], Control of wood dust from horizontal belt sanding. Am Ind Hyg Assoc J 46(10):567-577) have been submitted to the docket as Appendix F. c -24- SL 061936 *) REFERENCES Enterline PE, Marsh GM, Henderson V, Callahan C [1987]. Mortality update of a cohort of U.S. man-made mineral fibre workers. Ann Occup Hyg 31(48):625-656. NIOSH [1983]. NIOSH comments to OSHA Docket H-160; Health standards: Methods of compliance, June 1983. Stanton MF, Layard M, Tegeris A, Miller E, May M, Morgan E, Smith A [1981]. Relation of particle dimension to carcinogenicity in amphibole asbestoses and other fibrous minerals. JNCI 67(5):965-975. Walton WH (ed) [1987]. Man-made mineral fibres in the working environment. J_n: The Annals of Occupational Hygiene. Oxford, UK: rergamon Press. -25- SL 061937 DEPARTMENT OF HE \ LTH i- HI MAN ''EKV ICES Public Heaitb Ser..ce Centeri fc D ^eaie Control Mat onjl In^t'tu'a `or 0'.C..Iir o a S.r-1' , i H-i -n Sob-rr A T.irr L_:)o' j;cr a; 4676 Coium:ra Pjik.vay Cine,mati OH 45226-1998 July 25, 1988 Mr. Thomas Hall OSHA Division of Consumer Affairs Docket No. H-020 U.S. Department of Labor Room N-3647 200 Constitution Avenue, N.W, Washington, D.C. 20210 Dear Mr. Hall: Enclosed is the National Institute for Occupational Safety and Health's (NIOSH's) testimony to the OSHA Docket Office in support of the proposed rule on Air Contaminants [53 FR 20960]. The following items are also enclosed with this letter: 1. Seven tables consisting of the following (4 copies): Table N1 Proposed PELs (NI0SH concurrence) Table N2 Proposed PELs (NI0SH non-concurrence) Table N3A Established PELs Not Addressed in Current Rulemaking (NIOSH Concurrence) Table N3B Established PELs Not Addressed in Current Rulemaking (NIOSH non-concurrence) Table N4 Nuisance Dusts Table N5 NIOSH RELs Not Included in OSHA Rulemaking Table N6A Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen" (NIOSH concurrence) Table N6B Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen" Table N7 Proposed PELs as TWAs for which NIOSH Recommends a Ceiling 2. Individual folders on substances with which NIOSH has specific comments and supporting references (4 copies each) 3. Health Hazard Evaluations (HHEs) on all chemicals within the scope of this rulemaking (1 paper copy and 3 microfiche copies) SL 061938 (I Page 2 - Mr. Thomas Hall Ia a separate delivery, NIOSH is submitting paper copies of all toxicity references contained with the Registry of Toxic Effects for Chemical Substances (RTECS) If you have any questions, please call me at FTS 684--8302 or 513/533-8302. Sincerely yours Richard A. Lemen Director Division of Standards Development a'd Technology Transfer SL 061939 TESTIMONY OF THE NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH ON THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION'S PROPOSED RULE ON AIR CONTAMINANTS 29 CFR Part 1910 Docket No. H-020 Presented at the OSHA Informal Public Hearing August 2, 1988 Washington, D.C. J. Donald Mi Ilar, M.D. Assistant Surgeon General Director National Institute for Occupational Safety and Health SL 061940 0 NIOSH staff presenting for Or. Mil lar: Richard A. Lemen Di rector Division of Standards Development and Technology Transfer (DSDTT) Richard W. Niemeier Deputy Director Laurence D. Reed Acting Associate Director for Policy Development Office of the Director, DSDTT * Office of the Director, DSDTT Theodore J. Meinhardt Assistant to the Director Office of the Director, DSDTT Ralph D. Zumwalde Assistant Chief Document Development Branch, DSDTT Robert W. Mason Biologist Division of Biomedical and Behavioral Science Lawrence Fine Director Division of Surveillance, Hazard Evaluations and Field Studies (DSHEFS) Dawn G. Tharr Chief Industrial Hygiene Section, Hazard Evaluations and Technical Assistance Branch, DSHEFS Paul E. Cap Ian Research Industrial Hygienist Engineering Control Technology Branch, Division of Physical Sciences and Engineering (DPSE) Donald D. Dot 1 berg Research Chemist Measurements Development Section, Measurements Research Support Branch, DPSE Nancy J. Bollinger Chief Chief, Certification Branch, Division of Safety Research Thomas Hodous McU i i-a 1 Officer Medical Section, Clinical Investigations Branch, Division of Respiratory Disease Studies SL 06194^ I am Richard A. Lemen, Director of the Division of Standards Development and Technology Transfer (DSDTT) of the National Institute for Occupational Safety and Health (NIOSH). With me today are senior staff from NIOSH research divisions, each of whom has expertise in various aspects of this rulemaking. Our purpose for appearing at this hearing is to support the Occupational Safety and Health Administration's (OSHA's) efforts to promulgate a new standard. NIOSH may make comments or recommendations in addition to those contained in this testimony, based upon other information presented during this hearing. I want to take this opportunity to commend OSHA for embarking upon this rulemaking effort. This comprehensive updating of the Z-Tables will directly influence the health of all American workers. NIOSH strongly supports OSHA in its desire to make the air contaminant standards consistent with the most current information. We agree that there is an urgent need to update the current air contaminant standards because they represent exposure limits based on data available prior to 1968. Current information on health effects indicates that more protective limits are required for many substances. Even though NIOSH will question some of the specific Permissible Exposure Limits (PELs) that have been proposed, NIOSH does not question the wisdom of this rulemaking. Although NIOSH will suggest that some proposed PELs are not optimal, NIOSH nevertheless advocates adoption of more protective PELs. Even if some PELs are SI- 061942 less protective than NIOSH might prefer, the overall impact of this Z-Table update represents a significant advance for worker safety and health. On the other hand, it should be clearly understood by all tnai this rulemaking is an exceptional event made necessary by the passage of 20 years without significant reevaluation of the standards contained in the Z-Tables. This should in no way impede vigorous action in the future to promulgate comprehensive standards as specified under Section 6(b) of the Occupational Safety and Health Act. Instead this should serve as an i^oetus to proceed more swiftly and efficiently with comprehensive stani.. Is. NIOSH has transmitted to the Department of Labor 129 Criteria Documents and 50 Current Intelligence Bulletins (CIBs) (of these, one Criteria Document and one CIB were transmitted after this rulemaking was initiated). NIOSH Criteria Documents and CIBs are unparalleled in terms of the amount of information considered, the detail to which that information is examined, the extent to which evaluations are subjected to external peer review prior to publication, and the care with which those evaluations are explained in the published recommendation. It is important that the record is clear on what a Niuon Criteria Document represents in this regard. Criteria Documents are based on comprehensive reviews of the world's scientific literature. They routinely cite over 100 references and <t -2SL 061943 *y many cite several hundred. NIOSH does not rely upon information that cannot be made public. Critical evaluations of cited references with detailed discussions of their implications are included in Criteria Documents to provide the reader with an appreciation of their strengths, their weaknesses, and a clear description of how NIOSH interprets these publications. By this method, the reader has enough information to reach independent conclusions regarding these cited reports. Each draft Criteria Document is reviewed by experts representing affected industries, organized labor, and trade or professional organizations, and by scientists, physicians, and other health professionals with related experience in academia, government, or industry. The number of these external peer reviewers normally is greater than 10 and often exceeds twice that number. In addition to the invaluable contribution their comments make to the completed Criteria Document, OSHA receives, along with the completed Criteria Document, the full text of each reviewer's written comments accompanied by itemized annotations indicating how the draft was modified in response, or providing the rationale if the comment or recommendation was not adopted. Each Criteria Document contains an extensive summary in which the basis for the Recommended Exposure Limit (RED is carefully developed with clear and explicit citation of the data relied upon at all steps of the logical development. No other source of exposure limits approximates the comprehensiveness of these documents. -3- SL 061944 N1 OSH recommends that the chemical universe defined for the present rulemaking should include all chemicals covered by NI OSH RELs. We recognize the practical necessity for OSHA to limit the universe of ^"micals subject to this rulemaking, but as noted by OSHA in its preamble, there are relatively "few instances" of substances with a NIOSH REL but no TLV*. Including these substances would not significantly affect the "boundary on the number of substances to be evaluated," a concern expressed by OSHA in the notice for proposed '"lemaking. NIOSH Table N5 (Appendix A) sts these 42 chemicals excluded up to now from the Z-Table upda if these are nc added to the current update, they should be targeted or priority rulemaking to begin immediately upon completion of the present effort. For a large number of the chemicals covered by this rulemaking (277 to be exact), NIOSH concurs with the PEL being proposed by OSHA. These chemicals are listed in NIOSH Table N1 (Appendix A). For them, the available documentation appears to support the proposed exposure limits as adequate to protect workers from recognized health hazards. NIOSH questions the proposed PELs for the 31 chemicals listed in iauie n2. They are: 1) Acrylic acid (HS 1009) 2) n-Butyl glycidyl ether (BGE) (HS 1052) (. * -4SL 061945 3) Camphor, synthetic (HS 1063) 4) Caprolactam vapor (HS 1065) 5) Coal dust (<5% quartz) (HS 1096) 6) Coal dust (>5% quartz) (HS 1097) 7) Disulfoton - skin (HS 1152) 8) Ethyl bromide (HS 1163) 9) Ethyl ether (HS 1164) 10) Ethylene glycol vapor (HS 1169) 11) Fenthion - skin (HS 1175) 12) Fluorine (HS 1179) 13) Formamide (NIC - skin) (HS 1182) 14) Furfural - skin (HS 1183) 15) Heptane (n-Heptane) (HS 1194) 16) Hexane isomers (HS 1201) 17) 2-Hexanone (Methyl n-butyl ketone) (HS 1202) 18) Isopropoxyethanol (HS 1223) 19) Isopropyl acetate (HS 1224) 20) Isopropylamine (HS 1228) 21) Manganese tetroxide (HS 1238) 22) Mesityl oxide (HS 1243) 23) Octane (HS 1296) 24) Ozone (HS 1301) 25) Pentane (HS 1306) 26) 2-Pentanone (Methyl propyl ketone) (HS 1307) 27) Silica--Amorphous diatomaceous earth (HS 1352) 28) m-Toluidine - skin (HS 1401) 29) Triethylamine (HS 1408) 30) Vinyl acetate (HS 1424) 31) Zirconium compounds, as Zr (HS 1439) Examples of reasons for NIOSH's concern for the chemicals from NIOSH Table N2 are given for the following 2 substances. 1. Ethylene Glycol (EG) OSHA currently does not have a PEL and proposes a 50 ppm ceiling as the new PEL as recommended by the ACGIH. In the NIOSH review of EG we have found that positive rat and mouse teratogenicity for -5- SL 061946 oral administration of EG has been reported by Lamb et al. [1985] Price et al. [1985], and Hardin et al. [1987]. The summary statement by C. Price is germane to OSHA's consideration of PELs: "The lack of apparently serious maternal effects at the lowest dose which produced malformation in both species, as well as the severity and frequency of fetal defects at higher doses, suggest that EG may carry a selective risk to the embryo and should be considered a potential development hazard in situations where major EG exposure is likely to occur." The interpretation of the human iteers) inh tion exposure study by Wills et al. [1974], a? . mating a 50 ppm ceiling (125 3 mg/m ) TLV, is questioned. Revie* of the reported study indicates the most common complaint was irritation of the upper respiratory tract during the 30-day, 20-22 hours per day exposures at mean daily concentrations ranging from 3 to 67 mg/m (1.4-27 ppm) and the irritative phenomena became common when the 3 concentration was raised to about 140 mg/m (56 ppm). Despite the significantly erratic exposure concentrations during the 30 days of "continuous" exposure, the reported irritation would indicate that a 50 ppm limit does not offer sufficient protection from respiratory irritation. The potential teratogenicity and the known respiratory irritation at the proposed level suggests that OSHA reconsider their proposed PEL. / -6SL 061947 In addition, the OSHA Summary of Toxicology should be corrected to read for the Wills et al. study [page 21035 of the Federal Register notice, 2nd column, 19 lines from the top]: "In a human inhalation study, Wills and colleagues [1974] reported that volunteers exposed to the aerosol from 20 to 22 hours per day for 3 4 weeks, at mean daily concentrations between 3 and 67 mg/m (1.4-27 ppm) complained of throat irritation, and on occasion mild headache`and lower back pain." 2. Ethyl Ether OSHA proposes to add a STEL to their current PEL of 400 ppm for Ethyl Ether. The current PEL is the same as the ACGIH TLV and the STEL of 500 ppm is also recommended by ACGIH. ACGIH set a TLV of 400 ppm TWA and a 500 ppm STEL based upon workers developing a tolerance to irritation at that level [ACGIH 1986]. Nelson et al. [1943] tested human subjects for a period of 3 to 5 minutes for sensory responses to ethyl ether and reported, "Complaints of nasal irritation began at 200 ppm. Three hundred was objectionable as a working atmosphere." It was further suggested that 100 ppm was the highest concentration which the majority of subjects estimated satisfactory for 8-hour exposure and 200 ppm was a level which produced nasal irritation in a majority of subjects. Nelson stated that the study reported is "not sufficient" to act as a basis for new limits. However, it would -7- SL 061948 appear that a 400 ppm TWA may protect workers from systemic effects, but would not prevent irritation to some individuals. The concerns for the remaining 29 substances on NIOSH Table N2 have been submitted to the docket with NIOSH's written testimony. Some of the chemicals in the universe defined by the 1986 ACGIH TLV list have been excluded from this rulemaking by OSHA for a variety of reasons. NIOSH concurs with OSHA's determination on 127 substances listed in NIOSH Table N3A (Appendix A) as not needing further revisions based on available data, but believes that those listed in NIOSH Table N3B (Appendix A) should be included in this rulemaking. NIOSH has identified 9 chemicals in NIOSH Table N3B which are of concern. They are: 1) Acetylene tetrabromide (HS None) 2) Chlorobenzene (HS None) 3) Chromium (II) compounds, as Cr (insoluble) (HS None) 4) Chromium (III) compounds, as Cr (insoluble) (HS None) 5) Cresol, a! isomers - skin (HS None) 6) Manganese *t & compounds (HS None) 7) Molybdenur is Mo (soluble compounds) (HS None) 8) Nitromethare (HS None) 9) Parathion - skin (HS None) Cresol will serve as an example of NIOSH's concern. The OSHA PEL and the ACGIH TLV [ACGIH 1986] for cresol both have identical exposure 3 limits of 5 ppm (22 mg/m ), TWA, with a skin notation; therefore, lists chemical is not being considered for revision. However, NIOSH 1 -8SL 061949 3 has established an REL of 2.3 ppm (10 mg/nr), TWA, which should be considered in the revision of the OSHA standards. In 1952, ACGIH established a 5 ppm TWA based on an analogy with phenol [ACGIH 1986]. The toxicity of cresol compared to phenol was considered in two studies [Fairhall 1957; Hamilton et al. 1949], It was believed the 5 ppm level would protect against irritation, and kidney and liver damage. NIOSH [1978] established an REL of 2.3 ppm (TWA). NIOSH reported that although the data indicates similarities in toxicity between cresol and phenol when they are given by several routes of exposure, other evidence suggests that cresol is more toxic by inhalation [Uzhdavini et al. 1972]. The findings of Deichmann et al. [1963] agreed with Uzhdavini concerning the adverse effects of cresol below 20 mg/m . The NIOSH REL is more protective than the current OSHA PEL or TLV. NIOSH's concerns for the other 8 substances are attached to our written comments and are in the OSHA docket. In NIOSH Table N4 (Appendix A), NIOSH has identified 48 substances which OSHA is proposing to regulate as nuisance dusts. OSHA is proposing permissible exposure limits (PELs) for 47 substances (Table C10-1) that are currently regulated by OSHA's PEL for nuisance dust (15 mg/m3 for total dust and 5 mg/m3 for respirable dust). The -9- SL 061950 proposed PELs are 5 mg/m3 for fibrous glass dust and 10 mg/m3 for the remaining 46 substances. The 10-mg/m PELs are based on the TLVs established for these substances by ACGIH. Exposure to these wo;,ranees is considered to cause adverse "nuisance" effects, including interference with vision, irritation of the upper respiratory tract and skin, and deposits of these substances in the eyes, ears, and nasal passages. Reactions of lung tissue to these substances are considered to be reversible when exposure ceases. NIOSH has conducted a limited evaluation of the literature on the 48 substances in Table N4 and has concluded that the documentation 3 cited by OSHA is inadequate to support the proposed PEL of 10 mg/m for many of the substances. Recent toxicologic and exposure data indicate that exposure to some of these substances may cause cancer or other serious adverse health effects. Adherence to the proposed PEL cf 10 mg/m (total dust) would not prevent the toxicologic effects associated with many of these substances. NIOSH is therefore concerned that it is misleading to apply term "nuisance dust" to such substances. ,,,^on is also concerned that total dust exposure may be an inanoropriate criterion for assessing the relationship between exposure and effect. The 48 substances considered here are present in occupational environments within a respirable size range, and the ratory system is therefore the most likely route of exposure. </ -10- SL 061951 However, differences in particle morphology and size affect pulmonary defense mechanisms differently. Furthermore, solubility and pH must be determined to assess the effects of some substances on the mucous membranes. All the characteristics of a substance need to be assessed when determining its potential toxicity. For substances that typically become airborne in the workplace as respirable particulates, a PEL based on the respirable fraction of the substance would be warranted. Substances that exhibit a toxic effect upon contact with mucous membranes may more appropriately require exposure limits for both total and respirable particulates. NIOSH is further concerned that exposure to several of the substances listed in Table C10-1 may involve concomitant exposure to free silica, which may cause silicosis or lung cancer. OSHA has proposed that the PEL for these substances be applied only when the quartz content is less than 1 percent. This criterion may understate the risk of airborne exposure to quartz, since the percentage of quartz is typically determined by anafysis of the raw material or of the settled dust and not by analysis of airborne samples. Airborne samples should be collected and analyzed for free silica whenever workers are exposed to quartz or to any of the substances associated with free silica. Exposure to free silica should be limited to concentrations below the NIOSH REL of 50 ug/m3. -11- SL 61952 NfOSH is particularly concerned that toxicologic evidence demonstrates a relationship between exposure to certain substances listed in Table C10-1 and chronic respiratory disease, including cancer. Clear evidence of chronic respiratory disease has been observed in workers exposed to various types of mineral fibers [Walton 1987]. Enterline et al. [1987] reported a statistically significant risk of lung cancer in workers exposed to glass and mineral-wool fibers. This risk of cancer was also observed in animals [Stanton et al. 1980] when fibers with various physical and chemical characteristics were implanted in the pleurae of rats. The ability of these fibers to induce cancer was discovered to be related to the length and diameter of the fibers and not to their chemical compositions. Rats dosed with fibrous glass, aluminum oxide, and silicon carbide exhibited a carcinogenic response similar to that of rats dosed with asbestos. The NIOSH evaluation of data on titanium dioxide indicates a risk of cancer from exposure. The incidence of tumors observed in animals exposed to titanium dioxide meets the OSHA criterion for potential occupational carcinogens (29 CFR 1990.103). Other data evaluated by NIOSH indicate that benomyl exposure may cause adverse reproductive clients and that magnesium oxide exposure may cause chronic respiratory disease. NIOSH has included pertinent literature on these substances as part of its submission, and OSHA should consider it in this rulemaking. -12- SL 061953 Having selected the TLV list as the universe to be considered, OSHA frequently limits its consideration of health effects to those that the ACGIH considered when establishing the TLV. The full range of available toxicologic, epidemiologic, and exposure information should be considered for all chemicals in the universe selected. The need to do so is most evident for chemicals that NIOSH and others consider to be carcinogenic. For a large number of these chemicals, OSHA proposes to establish a PEL without identifying the chemical as a potential occupational carcinogen. In some cases OSHA acknowledges without comment the conclusion by NIOSH or others that these chemicals are potential occupational carcinogens, but still does not so designate those chemicals. In some cases the limits proposed for adoption were based on carcinogenicity, in other cases they were based on other acute or chronic health effects. Even if OSHA chooses not to accept NIOSH recommendations that occupational exposure to carcinogens should be restricted to the lowest feasible level, OSHA should designate these chemicals as potential occupational carcinogens because these chemicals meet the criteria for carcinogenicity as established by OSHA [29 CFR 1990.103]. Chemicals that should be designated as potential occupational carcinogens are listed in NIOSH Tables N6A and N68 (Appendix A) and have been submitted to the OSHA docket with our written testimony. On Table N6A, NIOSH has identified 39 substances which have proposed PELs that NIOSH can agree with, but for which a carcinogen designation should be added to the PEL. The chemicals are: -13- SL 061954 1) Acrylamide - skin (HS 1008) 2) Aldrin - skin (HS None) 3) Amitrole (HS 1020) 4) Aniline & homologues - skin (HS 1025) 5) Anisidine (o-, p-isomers) - skin (HS None) 6) Captafol - skin (HS 1066) 7) Captan (HS 1067) 8) Carbon tetrachloride - skin (HS 1073) 9) Chlordane - skin (HS None) 10) Chloroform (HS 1036) 11) Dichloroacetylene (HS 1123) 12) OichloroethyI ether - skin (HS 1127) 13) Dichloropropene - skin (HS 1129) 14) Oieldrin - skin (HS None) 15) Diglycidyl ether (DGE) (HS 1139) 16) Dimethyl sulfate - skin (HS 1142) 17) Dinitrotoluene - skin (HS None) 18) Dioxane - skin (HS 1145) 19) Di-sec-octyl phthalate (HS 1116) 20) Ethylene dichloride (HS 1168) 21) Heptachlor - skin (HS None) 22) Hexachlorobutadiene - skin (HS 1195) 23) Hexachloroethane - skin (HS 1197) 24) Hexamethyl phosphoramide (HS None) 25) Methyl iodide - skin (HS 1259) 26) Nickel carbonyl (as Ni) (HS 1284) 27) Propylene imine - skin (HS None) 28) Silica - crystalline (cristobalite) (HS 1354) 29) Silica - crystalline (tridymite) (HS 1356) 30) 1,1,2,2-Tetrachloroethane - skin (HS 1385) 31) To I uene-2,4-di isocyanate (TDD (HS 1398) 32) o-Toluidine - skin (HS 1399) 33) 1,1,2-Trichloroethane (HS None) 34) Trichloroethylene (HS 1406) 35) 1,2,3-Trichloropropane - skin (HS 1407) 36) Uranium (insoluble compounds, as U) (HS 1418) 37) Uranium (soluble compounds, as U) (HS 1419) 38) Vinyl cyclohexene dioxide (HS 1426) 39) Wood dust, hardwood (HS 1430A) There are 53 chemicals on NIOSH Table N6B that not only should be designated as carcinogens, but for which there remains a substantial level of risk at the proposed PEL. The substances are: c* -14- SL 061955 1) Acetaldehyde (HS 1001) 2) Arsine (HS None) 3) Asphalt (petroleum) fumes (HS 1028) 4) 8enzo(a)pyrene (HS None) 5) Beryllium & compounds, as Be (HS 1033) 6) tert-Butyl chromate, as Cr03 - skin (HS None) 7) Carbon black (HS None) .8) Chlorinated camphene - skin (HS 1078) 9) ChIorodiphenyl (42% chlorine) - skin (HS None) 10) ChIorodiphenyl (54% chlorine) - skin (HS None) 11) Chromic acid and chromates (HS 1092) 12) Chromite ore processing (chromates), as Cr (HS None) 13) Chromium (VI) compounds, Cr (water soluble) (HS None) 14) Chromium (VI) compounds, Cr (certain water insoluble) (HS None) 15) Chromyl chloride (HS 1094) 16) Chrysene (HS None) 17) Coal tar pitch volatiles, as benzene solubles (HS None) 18) DOT (Dichlorodiphenyl-trichloroethane) (HS 1113) 19) p-Dichlorobenzene (HS 1125) 20) Dimethyl carbamoyl chloride (HS None) 21) 1,1-Dimethyl hydrazine - skin (HS None) 22) Epichlorohydrin - Skin (HS 1158) 23) Ethyl acrylate - Skin (HS 1161) 24) Ethyl chloride (HS None) 25) Gasoline (HS 1185) 26) Hydrazine - Skin (HS 1205) 27) Lead chromate (as Cr) (HS None) 28) Methyl bromide - Skin (HS 1253) 29) Methyl chloride (HS 1254) 30) Methyl hydrazine - skin (HS None) 31) 4,4'Methylene bis(2-chloroaniIine) - Skin (HS 1273) 32) Nickel Soluble or (inorganic) compounds, a Ni (HS 1283) 33) Nickel sulfide roasting, fume & dust (as Ni) (HS None) 34) p-Nitrochlorobenzene (HS 1288) 35) 2-Nitropropane (HS 1291) 36) Perchloroethylene (HS 1308) 37) N-Phenyl-beta-naphthylamine (HS None) 38) Phenyl glycidyl ether (PGE) (HS 1315) 39) Phenyl hydrazine - Skin (HS 1317) 40) Propane sultone (HS None) 41) Propylene dichloride (HS 1341) 42) Propylene oxide (HS 1344) 43) Rosin core solder pyrolysis products, as formaldehyde (HS 1350) Si Iica--Crystalline 44) Quartz (HS 1355) 45) Tripoli (HS 1357) 46) Silica, fused (HS 1358) 47) o-Tolidine - skin (HS None) 48) p-Toluidine - Skin (HS 1400) -15- SL 061956 49) Vinyl bromide (HS 1425) 50) Vinylidene chloride (HS 1428) 51) Welding fumes (HS 1430) 52) Wood Dust, softwood (HS 1430b) 53) Zinc chromate, s Cr (HS 1436) Some chemicals on NIOSH Table N6A and N6B have been excluded from this rulemaking by OSHA as is evident from their lack of a HS number. However, NIOSH concludes that OSHA should include these chemicals in this rulemaking. On NIOSH Table N7, NIOSH has identified substances for which OSHA intends to adopt a TWA instead of the ret. tended NIOSH Ceiling Value. NIOSH recommends that OSHA adopt the NIOSH Ceiling Values to provide the most appropriate degree of health protection. These substances are: 1) Butyl mercaptan (HS 1054) 2) Benzyl chloride (HS None) 3) Cyanides (as CN) - skin (potassium cyanide) (HS None) 4) Cyanides (as CN) - skin (sodium cyanide) (HS None) 5) Hydrogen sulfide (HS 1209) 6) Hydroquinone (HS tone) 7) Isopropyl glycidyl ether (IGE) (HS 1227) 8) Methyl chloroform (HS 1255) 9) Methyl mercaptan (HS 1263) 10) Petroleum distiIlates (naphtha; rubber solvent) (HS 1312) it; Phenol - skin (HS None) 12) Phenyl mercaptan (HS 1316) 13) Phosgene (HS None) 14) Vanadium (as V205) - respirable dust fume (HS 1421) 15) Vanadium (as V205) - fume (HS 1422) ir -16- SL 061957 Turning now to the specific questions posed in the NPRM: 1. Are substances included which should be excluded from this ruIemaking? No. On the contrary, substances were excluded which should have been included. Immediately upon completion of this rulemaking, OSHA should take action to establish PELS for all substances that are excluded from this rulemaking despite the existence of a formal NIOSH recommendation to OSHA. As a first step, OSHA should initiate consolidated rulemaking similar to the present Z-Table update to adopt all NIOSH RELs pending chemical-specific Section 6(b) rulemaking to establish comprehensive standards. 2. Is additional health and feasibility documentation available relative to the proposed PELS beyond that described in the preamble? Yes. OSHA has frequently limited itself to the documentation used by the ACGIH in support of TLVs. Whenever available, NIOSH Criteria Documents, Current Intelligence Bulletins, and Alerts should be considered by OSHA in its final rulemaking. For many of the chemicals, substantial databases are available from other governments (e.g., Germany, the United Kingdom, Sweden), as well as from organizations such as the International Labor -17- SL 6l958 Organization, the American Industrial Hygiene Association, the Nordic Expert Group for Documentation of Occupational Exposure Limits, and the National Library of Medicine. A large number of National Cancer Institute (NCI), National Toxicology Program (NTP), and International Research on Cancer (IARC) monographs on chronic bioassay reports are available that provide extensive information on acute and chronic systemic toxicity in addition to data on potential carcinogenicity. As part of this response, NIOSH k providing a chemical-by-chemical discussion with citations of the most pertinent supporting data that could be identified within the time limitations. For chemicals included in the PEL update, copies have been submitted to the docket of all pertinent NIOSH Health Hazard Evaluations (HHEs) as well as all citations for toxicity contained in the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS). These data are collected as mandated by Section 20(a)(6) of the Occupational Safety and Health Act o 70 (PL 91-596). These data are publicly available and will assist OSHA in fulfilling its obligation under the Occupational Safety and Health Act to consider "the latest available scientific data in the field." NIOSH has not attempted to provide OSHA with the other elements the Act requires OSHA to consider, namely, "... the feasibility of the standards, and experience gained under this and other health and safety laws." If -18- SL 061959 *J The HHE reports will provide some idea of exposures found during requested NIOSH evaluations in industry. NIOSH is continuing to develop information and will provide to OSHA other relevant data on exposure concentrations found in industry in our post-hearing comments. These data should assist OSHA in determining feasibility. In addition to these publicly available sources of information, OSHA should ask major employers throughout the country to provide listings of all of their own internal exposure limits along with their documentation of those limits. In many industries these may be more restrictive than existing OSHA PELs, and this should be an excellent source of information on feasibility of various Iimits. Because many of the proposed PELs are derived from TLVs, OSHA should obtain from the ACGIH all unpublished data that contributed to the establishment of those TLVs. OSHA should follow up on these unpublished data to make the record as complete as possible. Dimethyl Formamide (DMF), a compound from NIOSH Table N3A, is of particular interest to both NIOSH and OSHA because of recent published information concerning testicular cancer and liver -19- SL 061960 disease. NIOSH will provide to OSHA a summary of these data presently in preparation. 3. Are substances included in this rulemaking used in industries other than those described in the preamble? and 4. Are substances included in this rule*iking u.*d for purposes other than those described in the prr ible? NIOSH has previously supplied to OSHA at their request a printout of the complete NIOSHTIC data base file on approximately 260 chemicals to aid in the identification of additional industries using the chemicals in this rulemaking. NIOSH is continuing to search its data base files (National Occupational Hazard Survey [NOHS]) for additional information which will be provided during this rulemaking process. 5. Do alternative unpublished exposure guidelines exist, such as those used in private workplaces, which may be suitable for general usage? NIOSH is aware of the existence of internal exposure guidelines in a number of private workplaces. NIOSH surveyors in assessing I -20- SL 061961 t* ethylene oxide exposure often found internal workplace controls in the 1 to 2 ppm range when the OSHA PEL was 10 ppm. Some of the proposals for change by ACGIH incorporate workplace exposure limits being used in industry at the time of the change. Nickel carbonyl is an example. This documentation relates that a nickel refinery in Sudbury, Canada, begins treating their workers for nickel carbonyl poisoning when their blood level of nickel reaches 150 micrograms/Iiter. It is further noted that the factory sounds an alarm when air concentrations read 10 ppb and an evacuation alarm sounds at 80 ppb. In this case the TLV is 5 times the level thought to be safe. There are existing guidelines on exposure to radioactive materials published by the International Commission on Radiation Protection (ICRP) and by the National Commission on Radiation Protection, which are applicable to radioactive substances, specifically soluble and insoluble uranium in this rulemaking. Before considering unpublished data, OSHA should update the published information on which it is relying for this proposed rule. A cursory review indicates that 72% of the references cited by OSHA were published prior to 1980 and 35% prior to 1969. The latter is the publication date for the current Z-1 table. NIOSH has submitted a complete set of references for each of the substances under consideration from its RTECS data base. -21- SL 061962 6) Is there inf rmation regarding laboratory analytical procedures which nay be used in lieu of those suggested by OSHA (see appendix A) to determine exposure to air contaminants? If NIOSH has transmitted to OSHA all of its applicable analytical procedures. NIOSH would caution OSHA that in the "Sampling and Analytical Methods" table several existing NIOSH analytical methods have been'extended to compounds for which the suggested method has not been verified. Some of these compounds have markedly different chemical properties than the compound(s) for which the method was developed. These methods will reouire validation before use: Method NIOSH 1003 NIOSH S43 NIOSH 1400 NIOSH 1400 NIOSH 1603 NIOSH 1003 NIOSH 1020 NIOSH 1020 NIOSH 1003 NIOSH 1003 NiuoH 1500 NIOSH 1500 wiOSH 5021 NIOSH 2002 NIOSH S264 NIOSH 1500 2002 i. woii 2002 Validated for haiogenated H/C methyl methacrylate isopropanol isopropanol acetic acid haiogenated H/C 1.1.2-trichloro1.2.2-trifluoroethane 1.1.2-trichloro1.2.2-trifluoroethane haiogenated hydrocarbons haiogenated hydrocarbons hydrocarbons hydrocarbons terphenyIs aromatic amines ethyl si 1icate hydrocarbons aromatic amines aromatic amines Extension proposed by OSHA 1,3-dich1o rop ropene 2-hydroxy Ipropy 1 acrylate propargyl alcohol isooctyi alcohol trichloroacetic acid chloroacety lene orodifluoromethane ropentafluoroethane o-chlorostyrene o-chlorotoluene cyclopentane hexane isomers hydrogenated terphenyIs N-isopropyl ani1ine methyl si 1icate nonane p-toluidine m-toluidine HS # 1129 1211 1335 1220 1404 1123 1085 1087 1089 1090 1111 1201 1210 1229 1266 1293 1400 1401 -22- SL 061963 1I The following are corrections to the NIOSH Analytical Methods for PEL Update Table (pp. 21308-21312 of the Federal Register). No. Analyte 4 acetone 17 ammonia 20 ammonium sulfamate 63 carbon Dioxide 190 hexach1o rocyc1 open t adiene 304 petroleum disti1lates (naphtha) 392 1,2,3-trichloropropane Correct NIOSH Va1idated Method NIOSH 1300 Add NIOSH S347 NIOSH S348 NIOSH S249 NIOSH 2518 NIOSH 1550 NIOSH 1003 7) Are the proposed exposure limits for each substance appropriate? NIOSH has addressed comments on each exposure limit it believes to be inappropriate and submitted these comments with supporting data to the docket as specified by OSHA in part VI11 of the proposed rule. 8. Is additional information available for those substances for which ACGIH proposed a higher TLV which might affect OSHA's decision that such a change was not justified? This rulemaking is not an appropriate proceeding for raising any permissible exposure limit. The decision to raise an occupational exposure limit should only be made through a full 6(b) rulemaking procedure with adequate time for all concerned parties to respond. -23- SL 061964 NIOSH has exa all of the available addi onal scientific information c stances for which the ACGIH TLV is higher and has commentec nere appropriate. The only substance included on Table C16-1 (Federal Register, p. 21211) that OSHA proposes to raise is Fluorine (HS 1179), and NIOSH has submitted detailed comments on this chemical which demonstrate that OSHA was not justified in raising the proposed PEL. Additionally, OSHA inadvertently stated (on p. 21029 of the Federal Register) that the current OSHA PEL for Synthetic Camphor (HS 1063) is 2 ppm rather than 2 mg/m (0.3 ppm). Because of this error, OSHA proposed to adopt the ACGIH TLV and STEL, i.e. 2 and 3 ppm, respectively, which is approximately 7 times higher than the current PEL. 9. Should the implementation dates for some substances be delayed because of sampling/analytical limitations or short-term feasibility impact considerations? Delaying the implementation date would not be technology forcing with regard to reducing occupational exposures. However, it is extremely important to note that for many substances listed in the update there are no sampling and analytical methods available or the method given has not been validated by either NIOSH or OSHA. Also, many of the proposed methods are in-house <f -24- SL 061965 4 OSHA methods which are not available to NIOSH or the general public for evaluation. Finally, there are methods whose Limit of Quatitation cannot support the proposed PEL or STEL. These problems are critical and must be corrected for proper enforcement of the regulation. Therefore, it is important that NIOSH and OSHA work together on a method development scheme that will allow the appropriate validated methods to be developed in a prioritized fashion within the implementation of the regulation. Also, it is imperative that OSHA set a high priority for promulgating followup regulations that deal with these sampling and analytical issues. 10. Is there additional information relative to the OSHA plans to adopt some recommended 10-hour TWA REL's as an 8-hour PEL? A NIOSH REL "... determined as a time-weighted average (TWA) exposure for up to a 10-hour work day, 40-hour work week" first appeared in the 1973 Inorganic Arsenic Criteria Document. That document was developed during the energy crisis of the early 1970's, when many employers began using 10-hour work days as an energy conservation measure. Consideration was given to recommending a mathematical adjustment of TWA RELs based on a constant limitation of the Concentration x Time for 8-hour and -25- SL 061966 longer work days. For example, an 8-hour TWA of 100 ppm (100 ppm x 8 hr = 800 ppm hr) would convert to 80 ppm for a 10-hour day (800 ppm hr/10 hr = 80 ppm hr). The conclusion at the time was that, so long as the work schedule did not exceed 10 hours per day or 40 hours per week, there was not sufficient precision in the selection of exposure limits to justify the precision implied by that mathematical adjustment. Therefore, the same TWA REL was intended to be applied to 8-hour and 10-hour work days in a 40-hour work week. The action proposed by OSHA in this rulemaking relative tc se RELs is consistent with that original intent. A mathematical conversion in the opposite direction, i.e., converting a 10-hour TWA of 100 ppm (1000 ppm hr) to an 8-hour TWA of 125 ppm (1000 ppm hr), would be contrary to the original intent and would be opposed by NIOSH. 11. Does the most current scientific information generally support acceptance of the hypothesis that all C-5-8-Alkanes are not equally toxic because a metabolite of n-Hexane exhibits unique neurotoxic properties? It is generally accepted that the metabolite that is responsible for the neurotoxic effects of n-hexane is 2,5-hexanedione (2,5-HO), a gamma diketone. This compound is also a metabolite of methyl-n-butyI ketone (MnBK), but is not known to be a metabolite of other alkanes in the C-5 to C-8 group. 2,5-HD -26- SL 061967 produces axonal degeneration (so-called "central peripheral distal axonopathy") characterized by a breakdown of neurofilaments and their accumulation distal to Ranvier nodes in the neuron. The observable symptomatology is, in sequence, limb weakness, severe paralysis, and muscle degeneration. The observation of similar neuropathies after exposures to MnBK or n-hexane and the discovery of their common metabolite, 2,5-HD, suggested the specific hypothesis that it is the gamma spacing of the diketone in the molecule that is the necessary and sufficient characteristic for producing this type of neuropathy. It would be correct to state that 2,5-HD is the principal neurotoxic metabolite of n-hexane and MnBk. It should also be recognized that any gamma diketone or any compound that may be metabolized to a gamma diketone (e.g., 5-nonanone metabolized to 2,5-nonanedione) may be neurotoxic. It would be incorrect to conclude that the neurotoxic properties ascribed to n-hexane are unique to this compound. Other alkanes or related chemicals that are ultimately metabolized to a gamma diketone may have similar toxicity. 12) OSHA has proposed to use exposure lieits from two well-established sets of guidelines as a source of values to update the PELS. Is information available about alternative sources which OSHA night consider for this purpose? -27- SL 061968 In its preamble to this proposed rulemaking, OSHA referred to 9 alternative sources: International Labor Organization World Health Organization European Economic Community United Kingdom Occupational Exposure Limits West German Maximum Allowable Concentrations Swe *> Allowable Workplace Air Concentrations Japt - Permissible Exposure Limits American National Standards Institute American Industrial Hygiene Association Another possibility is the Nordic Expert Group for Documentation of Occupational Exposure Limits. NIOSH believes all of these should be considered as equal or superior to the ACGIH TLV list in terms of the the criteria I is ted by OSHA. No single source should be expected to stand alone as a comprehensive list of candidates for regulation. OSHA should construct its own comprehensive list by drawing information from all available sources. -28- SL 061969 t No single list is current in its entirety. Although the ACGIH TLV list is republished annually, it is a mistake to assume that every TLV is reconsidered annually. The annual republishing is only a mechanism whereby those TLVs that have been revised can be disseminated. The ACGIH does not claim to reevaluate every TLV on a regular schedule. Economic and technical feasibility may be considered by the ACGIH in developing TLVs, but those considerations, if any, are not defined in the documentation of TLVs. Feasibility information for PELs derived from agencies listed above would be comparable, in most cases, to that provided by the ACGIH in support of TLVs. OSHA should consider the availability and quality of documentation on a substance-by-substance basis and use all available documentation, rather than select an exclusive list of substances simply because that list consistently has some documentation. The fact that the alternative sources listed above do not originate in the U.S. should not disqualify them from consideration of applicability. They should be judged against what is required to protect workers from the known toxicity of each substance regulated. Only after determining the level of -29- SL 061970 control necessary to ensure a safe and healthy workplace should other factors be considered, Because they are limits that other officials have judged necessary to protect worker safety and health, NIOSH believes that OSHA should at least consider limits from all of the sources listed above. 13. OSHA has outlined its criteria for identifying special situations. Are alternative criteria available which might be used in lieu of these, or in addition to them? OSHA has identified five circumstances that it considers special situations: Situations one and two involve a comparison of the ACGIH TLVs to four alternate data bases--the United Kingdom 1987 Occupational Exposure Limits, the West German 1985 Maximum Allowable Concentrations, the Japanese 1983 Permissible Exposure Limits, and the Swedish 1984 Allowable Workplace Air Concentrations. OSHA Tables 1-F-C and 1-F-O, that are based on these comparisons, are not accurate. NIOSH has reviewed the pertinent data on selected substances on Tables 1-F-C and 1-F-D and have submitted comments on the appropriateness of the limits proposed. Jl -30- SL 061971 Situation three involves the substances where the current TLV exceeds the existing PEL. NIOSH has addressed this issue in the response to question 8. Situation four involves the circumstances where the available analytical methods are not adequate to measure the substance at the air concentration proposed. NIOSH has addressed this situation in the answer to question 9. In the fifth situation where recent information suggests that neither the TLV nor the REL is appropriate, NIOSH finds it difficult to identify the exact substances to which OSHA is referring. NIOSH has commented on those substances which, based on the best available scientific information, meet OSHA's occupational carcinogen definition. On other substances where recent information indicates that neither the TLV nor the REL is low enough to be adequately protective, OSHA should adopt the lower of the available limits and immediately schedule the substance for expedited rulemaking. OSHA has outlined three alternative procedures for dealing with substances requiring special attention. Are additional approaches available which might be used in lieu of these, or in addition to them? -31- SL 061972 NIOSH would support OSHA in its decision to adopt either the level proposed or such other level as the evidence presented to the record indicates as proper for these substances, and identify them as requiring possible followup rulemaking. NIOSH has endeavored to provide OSHA with the required data for selecting a proper limit for selected substances on Tables l-F-C and l-F-D. NIOSH concurs with OSHA that it is in the best interest of the worker to promptly provide such increased health protection as is indicated by the evidence in the record. OSHA has performed feasibility analysis for tha following substances, based on limited available information: Acetonitrile, Carbon disulfide, Carbon monoxide, Carbon tetrachloride, Chloroform, Ethylene dichloride, Ethylene glycol dinitrate, Fibrous glass dust, Hydrogen cyanide, Isophorone diisocyanate, Nitrogen dioxide, Nitroglycerin, Trichloroethylene. Is further information available which might be used to supplement the present findings regarding the feasibility of achieving these levels in the workplaces? From NIOSH research data, we are including a detailed engineering feasibility study (Appendix B) for those listed in the question, as well as for the following chemicals: Acetone, Chlorine, Styrene, and Sulfur dioxide. -32- SL 061973 *I 16. OSHA has made a preliminary assessment of the proposed rulemakings' impact on large and small establishments. The Act requires OSHA to determine whether a regulation will have a significant impact on a substantial number of small entities, pursuant to the Regulatory Flexibility Act of 1980, S U.S.C. 601 et seq. Is there additional information regarding implementation of this rule for small businesses and entities which OSHA should consider? NI OSH has no common t. 17. OSHA has proposed PEL'S for some substances where the basis of this proposal also includes a carcinogenicity designation (e.g., TLV with an A1 or A2 designation; REL with a Ca designation). Should OSHA include a similar carcinogen designation in the Z-4 Table in this rulemaking? Yes. For both the TLV$ and the RELs, the carcinogen designation is an inseparable part of the recommendation. OSHA should include carcinogen designations for all chemicals that meet the OSHA definition of "potential occupational carcinogen" (29 CFR 1990.103). 16. OSHA has preliminarily decided that for substances where the ACGIH TLV is a TWA and the NIOSH REL is a Ceiling Value which is -33- SL O6I974 the sane or on* half of tha TWA, OSHA will propose that the TWA be adopted as the PEL. Should this approach be modified in the final rulemaking? What approach should be used when the converse of this situation (TLV, Ceiling REL, TWA) exists? NIOSH would suggest that this question fails to recognize the essential differences between a time weighted average (TWA) and a CeiIing Value. A TWA is appropriate as a limit when the toxic effect of the substance is directly related to the total dose received in a daily exposure. Ceii ; values are intended to minimize toxic effects related to the peak exposure. Ceiling values are necessary when there are immediate acute responses to an air contaminant independent of the total daily dose or when chronic effects are dose-rate response related. In conjunction with a TWA, ceiling values are also used to minimize the total daily dose when there is intermittent occupational exposure, e.g., ethylene oxide. The simple numerical relationship that OSHA has proposed is not a scientifically sound basis for selecting between a TWA and a ceiling value. An analysis of the data supporting the proposed limit must be conducted on a case-by-case basis to discern which limit is appropriate. -34- SL 061975 N1 OSH has submitted specific comments on a substance-by-substance basis in this category to assist OSHA in selecting the appropriate limit. These substances are listed in the NI OSH Table N7 of the NIOSH comments. OSHA preliminarily plans to adopt a phased start-up schedule. This would include an initial start-up requirement permitting the use of alternate control methods for revised PEL'S, followed at a later date by the required use of control methods fully consistent with the methods of compliance priorities in effect at that time. OSHA will shortly be requesting comments on the hierarchy of controls. An alternate approach is to set compliance date for engineering controls based on final determinations of that rulemaking. OSHA solicits comments on those approaches and suggestions regarding appropriate times for the two proposed start-up dates. NIOSH believes that work practices and engineering controls such as substitution, isolation, and ventilation should be used to control occupational exposures to the fullest extent feasible. NIOSH believes that personal protective equipment should be worn only when engineering controls are not feasible such as during maintenance procedures. -35- SL 061976 NI OSH recommends that OSHA allow industry 6 months to come into compliance by any combination of control methods, and 2 years for compliance by the NIOSH recommended hierarchy of control methods [NIOSH 1983]. OSHA currently is recommending that industry be allowed 4 years to come into compliance by OSHA's hierarchy of control methods. Furthermore, NIOSH recommends that OSHA require staged implementation over the 2-year period of conversion to the hierarchy. This latter requirement would be technology forcing and it would minimize the occurrence of last minute requests to OSHA for variances to meet the conversion requirement. 20. OSHA requests comment on whether the establishment of margins of safety below lowest observed or no effect levels Is consistent with the concept of "significant risk," and on whether the specific margins of safety proposed for specific chemicals are appropriate. Margins of safety and safety factors are attempts to adjust for uncertainty in available data and knowledge. The use of a margin of safety or a safety factor approach to identify exposure limits does not estimate the human risk associated with those proposed exposure limits. Therefore, such an approach cannot be considered to provide protection against or to reduce "significant risk" (either in a general conceptual sense or in *J 36- SL 061977 the sense of any specific judicial precedent). Nonetheless, NIOSH recognizes that a thorough case-by-case evaluation for all major industrial agents may not be possible for a variety of reasons and the use of a margin of safety or a safety factor approach to identify exposure limits for those chemicals provide a pragmatic method to develop standards. The exception to this statement is that NIOSH does not believe such an approach should be used to identify an exposure limit for an adverse health effect that result from non-threshold processes (e.g., cancer). In developing its recommendations to OSHA, NIOSH conducts thorough evaluations of all research data, estimated human risks associated with specific exposures, the sensitivity of measurement and analytic methods, alternative technologies, technological feasibility of various exposure levels, background or ambient exposure leveis, methods of worker protection and many other factors pertinent to specific exposure agents or environments. NIOSH knows of no other method to develop reliable exposure limit standards that is consistent with NIQSH's responsibility from the OSHAct to assure as far as possible, every working man and woman in the Nation, safe and healthful working conditions. Since the use of a margin of safety or a safety factor approach does not address essential issues required to develop a reliable exposure limit, including evaluation of "significant risk," NIOSH recommends that any -37- SL 061978 standards developed by the use of a margin of safety or a safety factor approach be considered interim standards. NIOSH recommends that standards based on a margin of safety or a safety factor approach, as well as standards derived from a case-by-case evaluation, be periodically reviewed to determine what new information is available. NIOSH is not recommending specific margins of safety or safety factors on any chemical. 21. OSMA has identified sensory irritation, which causes rhinitis, cough, sputum production, chest pain, wheezing and dyspnea as material impairment of health. OSHA invites comments on this understanding. The recognition of sensory irritation as potentially being "material impairment of health" is consistent with the current scientific consensus related to health effects of environmental agents. Mucous membrane irritants can cause increased blink frequency and tearing; nasal discharge, congestion, and sneezing; and cough, sputum production, chest discomfort, wheezing, chest tightness, and dyspnea. Work environments often require levels of physical and mental performance considerably greater than IJ -38- SL 061979 encountered in daily living. Even in the absence of any permanent impairment, the symptoms listed can interfere with job performance and safety. Mucous membrane irritation can result in inflammation, which may lead to increased susceptibility to nonspecific irritants and infectious agents. For example, experimental ozone exposure in humans results in increased airway reactivity. Also, studies of exposure to environmental tobacco smoke have shown irritative symptoms and evidence of increased frequency of respiratory tract illnesses in young children and decreased pulmonary function in adults. The American Thoracic Society has identified several points relevant to the issue of respiratory tract irritation. 1. Does the effect interfere with normal activity of the individuaI? 2. Are there episodes of identifiable respiratory illness? 3. Does the effect result in an incapacitating illness? 4. Is there permanent respiratory injury? 5. Is there progressive respiratory dysfunction? -39- SL 061980 Particularly on the job, sensory irritation is clearly relevant to point 1. Mucous membrane irritation is associated.with respiratory illnesses, depending on the composition of specific exposure and on the dose, duration, and frequency of exposure. No universally applicable conclusion can be drawn at this time regarding the association between irritative symptoms and permanent injury of dysfunction. Where certain individuals show no measurable impairment after an exposure, even when experiencing irritative symptoms, others may develop identifiable dysfunction. Aside from the effects of irritation, mucous membrane exposure may result in absorption of a substance, with resultant systemic toxicity. An inflamed mucous membrane may be an even more effective route of absorption, either for the irritant or for other substances. Furthermore, injury to bronchopulmonary membranes can impair removal of particulates from the respiratory system. 22. The question also arises of whether odorants present material impairment of health. That issue also might arise In the context of other substances. Based on the evidence in the final record concerning this issue, OSHA will determine if the criteria detailed in section IV-C-16 have been met, and take appropriate action. OSHA requests comment on this issue. KI -40- SL 061981 I Odors emitted by industrial chemicals often play an important role in occupational safety and health. When odors can be detected before health effects occur, they may provide early warning of exposure. A number of chemicals have strong odors at concentrations which are otherwise minimally toxic. These odors may cause undue health concerns among exposed workers or may create safety hazards by distracting workers from their tasks. Strong odors in the workplace may also mask the presence of other, more toxic substances. Strong odors can produce irritation and/or nausea at high concentrations, although these effects may be reversible following cessation of exposure. Olfactory fatigue often occurs and should be considered a functional impairment that can result in increased worker exposure. Olfactory fatigue can reduce the wearer's ability to sense inadequate respirator performance of air-purifying respirators. 23. Is there exposure information available which can be supplied which will refine OSHA's estimates of employee exposures and over exposures to the substances being regulated? NIOSH is submitting for the current rulemaking all relevant Health Hazard Evaluation Reports (HHEs) to the docket. Appendix C is a comprehensive listing of HHEs.being submitted. We have also previously submitted to OSHA a copy of data tapes -41- SL 061982 from the National Occupational Health Survey (NOHS). NIOSH anticipates submitting to OSHA a comprehensive listing of pertinent NIOSH exposure information in our post-hearing comments. 24. Is there information available which can be supplied to improve or supplement the engineering controls identified as necessary in order to reduce exposure levels? Is there additional cost data which can be supplied to refine the annual costs associated with these controls? In addition to the material on engineering feasibility provided to OSHA relating to question 15, NIOSH is continuing to evaluate general engineering feasibility data for these substances in this rulemaking that meet OSHA's definition of a potential occupational carcinogen (29 CFR 1990). 25. Under what conditions,, involving which industrial processes, will respirators be needed during the start up period, for maintenance operations, or where other controls are infeasible in order to protect employees at the proposed exposure levels? Are respirators currently being used under the conditions identified, or would they need to be purchased? Please describe the type of respirator currently in use or needed. (1 -42- SL 061983 NIOSH concurs with OSHA's assessment in the Non-Regulatory Alternative Section that personal protective equipment should only be used "where it is impractical to apply engineering or work practice controls, or where these applications will not consistently reduce employee exposures below the proposed PEL'S." In these instances, NIOSH recommends that the NIOSH Respirator Decision Logic (Appendix D) be used to select the appropriate respirator. NIOSH has little quantitative information on which respirators are currently being used under the conditions specified by OSHA. A NIOSH contractor's report ("Preliminary Survey of Existing Data and Economic Overview of Respirator Industry," Granville Corporation, March 10, 1982) is submitted to the docket as Appendix E and provides limited data on the numbers and types of respirators sold in the United States. This report used respirator manufacturers' data on respirator sales in 1980 and published data on workers [i.e., Economic Report of the President, (U.S.G.P.O., Washington, 1981)] to make some estimates on the number of certified respirators being worn by workers in the U.S. The Granville report estimates that 19.1% of mining, manufacturing, and construction workers wore or had access to certified respirators in 1980. In addition, it was estimated that over 20 million manufacturing workers and almost 4.5 mi 11 ion construction workers, and more than 1 million miners -43- SL 061984 used certified respirators. The Granville report also indicated that SC8As, "disposables," and particulate and chemical cartridge respirators have "large and roughly equal market shares (ranging from 25 to 30%) in terms of total dollar sales" (Granville Report, p. 40). \1 26. As a result of simultaneously regulating many substances, what cost savings will be realized in purchasing new engineering controls? Are alternate engineering controls available to achieve the lower permissible exposure limits being proposed? NIOSH has no comment with regard to the costs of purchasing new engineering controls. Alternate engineering control methods are discussed in our responses to questions 15 and 19. 27. What is the current state of technology control and financing in firms which would need to comply with reduced exposure limits to wood dust? In addition to the information provided on the individual chemical comments for Wood Dust (H.S. 1430A and 1430B), several innovative designs and devices have been developed to control wood dust in sawing, cutting, sanding and shaping. These published NIOSH references (Huebener DJ [1987]. Dust controls for a wood shaper. Appl Ind Hyg 2(4):164-169; and Hampl V and -44- SL 061985 Johnston DE [1985]. Control of wood dust from horizontal belt sanding. Am Ind Hyg Assoc J 46(10);567-577) have been submitted to the docket as -45- SL 061986 REFERENCES Enterline PE, Marsh GM, Henderson V, Callahan C [1987], Mortality :r',nre of a cohort of U.S. man-made mineral fibre workers. Ann Occup Hyg 31(48):625-656. NIOSH [1983]. NIOSH comments to OSHA Docket H-160; Health standards: Methods of compliance, June 1983. Stanton MF, Layard M, Tegeris A, Miller E, May M, Morgan E, Smith A [1981]. Relation of particle dimension to carcinogenicity in amphibole asbestoses and other fibrous minerals. JNCI 67(5):965-975. Walton WH (ed) [1987]. Man-made mineral fibres in the working environment, in: The Annals of Occupational Hygiene. Oxford, UK: Pcrgamon Press. -46- SL 061987 APPENDIX A CHEHICAL NAME Acetic acid Acetic anhydride Acetone Acetonitrile - Skin Acetylsalicylic acid (Aspirin) Acrolein Allyl alcohol - Skin AUyl chloride Allyl glycidyl ether Skin Allyl propyl disulfide A1uni nun Alkyls (NOC*) Pyro powders Soluble salts Welding fumes HS NUMBER CAS NUMBER 1002 1003 1004 1005 64-19-7 108-24-7 67-64-1 75-05-8 1006 50-78-2 1007 1010 1011 107-02-8 107-18-6 107-5-1 1012 106-92-3 1013 1015 1017 1018 1019 2179-59-1 7429-90-5 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSH concurrence) Hi TWA STEL PEL ppm g/n3 ppn ng/n3 ppn ng/m3 10 25 15 37 10 25 C 5 C 20 5 20 750 1780 1000 2375 1,000 2.400 40 70 60 105 40 70 5 None 0.25 2 1 0.3 5 3 0.8 0.1 4 10 26 0.25 2 1 5 3 5 22 10 44 C 10 C 45 2 12 3 18 2 12 2 None 5 None 2 None 5 None j* July 25. 1968 REL 250 ppn (590 ng/m3) TWA 20 ppm (34 mg/n3) TWA 1 ppm (3.1 ng/m3) TWA; 3 ppn (9.3 mg/n3) ceiling (15 min} 9.6 ppm (45 mg/m3) ceiling (15 min) 1 SL 061988 CHEMICAL NAME HS NUMBER CAS HUMBER Ammonia 1021 7664-41-7 Ammonium chloride fume 1022 Atracine 1029 Bismuth telluride (Se-doped) 1034 Borates, tetra, sodium salts Anhydrous 1036 Decahydrate 1037 Pentahydrate 1036 Boron tribromide 1040 Bromacil 1041 Bromine 1042 Bromine pentaflouride 1043 Butane 1044 2-Butanone 1045 (Methyl ethyl ketone;HEK) 2-Butoxyethanol - Skin 1046 n-Butyl acetate 1047 12125-02-9 1912-24-9 1304-82-1 1303-96-4 10294-33-4 314-40-9 7726-95-6 77B9-30-2 106-97-8 78-93-3 111-76-2 123-86-4 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PEls (NIOSH concurrence) _LUf_____ TWA STEL ppm mg/m-* ppm mg/m3 PEL ppm mg/m3 25 18 35 27 50 35 10 20 15 5 None 5 None 1 None 5 1 C 1 C 10 None 1 10 None 0.1 0.7 0.3 2 0.1 0.7 0.1 0.7 None BOO 1,900 None 200 590 300 B85 200 59Q 25 120 50 240 150 710 200 950 150 710 July 25. 1988 REL 50 ppm (34.8 mg/m3) ceiling (5 min) 200 ppm (590 mg/m3) TWA SL 061989 2 CHEMICAL NAME HS NUMBER CAS NUMBER Butyl acrylate sec-Butyl alcohol tert-Butyl alcoho) n-Butyl alcohol - Skin n-Butyl lactate o-sec-Butylphenol - Skin p-tert-Butyltoluene Calcium cyanamide Calcium hydroxide Calcium oxide Caprolactam Oust Carbofuran Carbon dioxide 1048 1049 10S0 1051 1053 1055 )056 1058 1059 1060 1064 1068 )069 141-32-2 78-92-2 75-65-0 71-36-3 138-22-7 89-72-5 98-51-1 156-62-7 1305-62-0 1305-78-8 105-60-2 1563-66-2 124-38-9 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table HI - Proposed PELs (NIOSH concurrence) IDt TWA STEL PEL ppm mg/a3 ppm mg/a3 ppm mg/a3 10 55 None 100 305 150 455 150 450 100 300 150 450 100 300 C 50 C 150 100 300 5 25 None 5 30 None 10 60 20 120 10 60 0.5 None 5 None 25 1 3 None 0.1 None 5,000 9,000 30,000 54,000 5,000 9,000 July 25, I960 REL 10,000 ppm (18,000 mg/a3) TWA; 30,000 ppm (S3.000 mg/a3) ceiling (10 min) SL 061990 3 CHEMICAL NAME Carbon disulfide - Skin Carbon monoxide Carbon tetrabromide Carbonyl fluoride Catechol Cesium hydroxide Chlorine Chlorine dioxide 1-Chloro-l-nitropropane Chloroacetyl chloride o-Chlorobemylidene malononitrile - Skin HS NUMBER 1070 1071 1072 1074 1075 1077 1079 1080 1081 1083 1084 CAS NUMBER 75-15-0 630-06-0 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSH concurrence) 1LV TWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 10 30 20 ppm TWA 30 ppm Cei1ing, 100 ppm Max Ceiling, (30 min) 50 55 400 440 50 55 558-13-4 0.1 353-50-4 2 120-80-9 5 21351-79-1 7782-50-5 1 (NIC 0.5 10049-04-4 0.1 600-25-9 2 79-04-9 0.05 2698-41-1 C 0.05 1.4 5 20 2 3 1.5 0.3 10 0.2 C 0.4 0.3 5 4 15 39 1 3) 0.3 0.9 None None None None Cl C3 0.1 20 None 0.05 0.3 100 0.4 July 25. 1988 REL 1 ppm (3 mg/m3) TUA; 10 ppm (30 mg/m3) ceiling (15 min) 35 ppm (40 rng/m3). 8-hr TUA; 200 ppm (229 mg/m3) ceiling (No defined time) 0.5 ppm (1.45 mg/m3) ceiling (15 min) SL 061991 4 CHEMICAL NAME HS NUMBER CAS NUMBER Chiorodifluoroaethane Chloropentafluoroethane Chloroprene - Skin 1065 1087 1088 75-45-6 76-15-3 126-99-8 o-Ch)orostyrene o-Chlorotoluene - Skin Chlorpyrifos - Skin Chromium Hetal as Cr Cobalt carbonyl, as Co 1089 1090 1091 1093 2039-87-4 95-49-8 2921-80-2 7440-47-3 1098 10210-68-1 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table Nl - Proposed PELs (NIOSH concurrence) TLV IMA STEL PEL ppm mg/m3 PP mg/m3 ppm mg/m3 1,000 3,500 1,250 4,375 None 1,000 6,320 None 10 35 25 90 50 285 75 430 None 50 250 75 375 None 0.2 0.6 None 0.5 1 0.1 0.1 Cobalt hydrocarbonyl, as Co 1099 16842-03-8 0.) 0.1 Cobalt, as Co Hetal dust t fume 1)00 7440-48-4 0.05 0.1 SL 061992 5 July 25, 1968 REL 1 ppm (3.6 mg/m3) ceiling (15 min) NIOSH has concluded that there is insufficient evidence to warrant recom mending a new exposure limit NIOSH has concluded that there is insufficient evidence to warrant recom mending a new exposure limit NIOSH has concluded that there is insufficient evidence to warrant recom mending a new exposure limit CHEMICAL NAME HS NUMBER CAS NUMBER C,,, . fume 1101 Crufornate 1103 Cyanamide 1104 Cyanogen 1105 Cyanogen chloride 1106 Cyclohexanol - Skin 1107 Cyclohexanone -Skin 1108 Cyclohexylamine 1109 Cyclonite - Skin 1)10 Cyclopentane 1111 Cyhexatin 1112 Decaborane - Skin 1114 2,6-di-tert-butyl-p-cresol 1117 Diazinon -Skin 1118 Dibutyl phosphate 1119 7440-50-8 299-86-5 420-04-2 460-19-5 506-77-4 108-93-0 108-94-1 108-91-8 121-82-4 287-92 13121-70-5 17702-41-9 128-37-0 333-41-5 107-66-4 Tabulation of KIOSK Reviews t-f Proposed PELs NIO ill Tf ble N1 - Propi sed PELs 1NI0SH concurrence) lilt TWA (,TEL ppm mg/3 ppm mg/m3 PEL ppm mg/m 10 C 0.3 50 25 10 u00 0.05 0.2 5 2 20 C 0.6 200 100 40 1.5 1 .720 5 0.3 10 0.1 5 20 3 0.15 0.9 2 10 None None None None 50 50 None None None None 0.05 None None 0.1 200 200 0.3 5 July 25. 1988 <EL 25 ppm (100 mg/m*) fUA SL 061993 6 CHEHICAL NAHE HS NUMBER CAS NUMBER 2-N-Oibutylaminoethanol Skin 1120 1,1-Dichtoro-l-nitroethane - 1121 $k i n 1,3-0ichloro-5,5dimethyl hydantoin 1122 1,1-Oichloroethane 1126 Dichloromonofluoromethane 1128 2,2-Pi chioropropionic acid 1130 Oicrotophos (Bidtin) - Skin 1131 Oicyclopentadiene 1132 Diethanolamine 1134 Diethyl ketone 1135 Diethyl phthalate Diethyl amine 1136 1137 Diethylene triamine - Skin 1138 Oiisobutyl ketone 1140 102-01-0 594-72-9 11B-52-5 75-34-3 75-43-4 75-99-0 141-66-2 77-73-6 111-42-2 96-22-0 84-66-2 109-89-7 111-40-0 108-83-8 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSH concurrence) lilt TWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 2 14 Hone 2 10 C 10 C 60 0.2 0.4 0.2 200 810 250 1,010 100 400 10 40 1.000 4,200 '6 0.25 None None 5 30 None 3 15 Hone 200 705 None 5 None 10 30 25 75 25 75 14 None 25 150 50 290 SL 061994 7 July 25, I960 REL 25 ppm (MO mg/m3) TWA CHEMICAL NAME HS NUMBER CAS NUMBER Dimethyl 1,2-dibromo- 1141 2,2-dichloroethyl phosphate (Haled Oibrom) - Skin Dimethylani1ine (N,N-0imethyl aniline) 1143 Dim tolnide 1144 Dioxathion - Skin 114b Diphenylamine 1147 Dipropyl ketone 1146 Oipropylene glycol methyl ether 1149 Diquat 1150 Oisulfiram 1151 Diuron 1153 Divinyl benzene 1154 Endosulfan - Skin 1156 Ethanol amine 1159 300-76-5 121-69-7 148-01-6 78-34-2 122-39-4 123-19-3 34590-94-8 85-00-7 97-77-8 330-54-1 1321-74-0 115-29-7 141-43-5 Tabulation of NI0SH Reviews of Proposed PELs NI0SH Table Nt - Proposed PECs (NI0SH concurrence) TLV TWA S1EL ppm g/m^ ppm mg/m^ PEL ppm mg/*^ 33 5 25 10 50 5 25 5 Hone 0.2 Hone 10 None 50 235 None 100 600 150 900 100 600 0.5 None 2 None 10 None 10 50 None 0.1 None 3 8 6 15 36 SL 061995 8 July 25, 1968 CHEMICAL NAME HS NUMBER CAS NUMBER Ethion (Nialate) - Skin Ethyl benzene Ethyl mercaptan (1-ethanelhiol) 1160 1162 1165 563-12-2 100-41-4 75-08-1 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs {NIOSH concurrence) TLV TWA STEL PEL ppm mg/m^ ppm mg/m^ ppm mg/m-* 0.4 Hone 100 435 125 545 100 435 0.5 1 C 10 C 25 Ethyl silicate 1166 Ethylene chlorohydrin - Skin 1167 Ethylene glycol dinitrate - 1170 Skin 78-10-4 107-07-3 628-96-6 Ethylidene norbornene M-Ethylmorpholine - Skin Fenamiphos - Skin fensulfothion (Dasanit) Ferrovanadium dust 1171 1172 1173 1174 1177 16219-75-3 100-74-3 22224-92-6 115-90-2 12604-56-9 10 C1 0.05 85 C3 0.3 C 5 C 25 5 23 0.1 0.1 1 100 850 5 16 0.2 l None 20 94 Hone Hone 31 July 25, 1988 REL 0.5 ppm (1.3 mg/m-*) ceiling (15 min) Mixtures of thiols to be controlled by calculation of equivalent concentrations 0.1 mg/nr* ceiling (20 min) recommended limit for either substance alone or mixtures 9 SL 061996 CHEMICAL MAKE MS NUMBER CAS DUMBER fluorotrichioromethane (Trichiorofluoromethane) 1180 fonofos - Skin 118) Furfuryl alcohol - Skin 1184 Germanium tetrahydride 1186 Glutaraldehyde 1187 Glycidol 1189 Grain dust (oats, wheat, barley) 1190 Graphite (natural) 1191 75-69-4 944-22-9 96-00-0 7762-65-2 111-30-8 556-52-5 7782-42-5 Hexachlorocyclopentadiene 1196 Hexafluoroacetone - Skin 1196 Hexane (n-Hexane) 1200 Hexone (Methyl isobutyl ketone) 1203 Hexylene glycol 1204 77-47-4 684-16-2 110-54-3 108-10-1 107-41-5 Tabulation of N10SH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSII concurrence) TLV TWA STEL ppm mg/m-* ppm mg/m* PEL ppm mg/m* C 1,000 C 5,600 Hone July 25, 1968 PEL 10 0.2 C 0.2 25 0.1 40 15 60 0.6 C 0.7 75 4, Total particulate None 50 None None 50 None 200 150 50 ppm (200 mg/m*) TWA 2.5 Respirable dust (NIC 10 Total dust) 0.01 0.1 0.1 0.7 50 180 50 205 75 300 C 25 C 125 2.5 Respirable dust None None 500 100 1,000 410 None 50 ppm (200 mg/m*) TWA SL 061997 10 CHEMICAL NAME HS NUMBER CAS NUMBER Hydrogen bromide Hydrogen cyanide - Skin 1206 1207 10035-10-6 74-90-8 Hydrogen fluoride> as f 1208 7664-39-3 Hydrogenated terphenyls 1210 2-Hydroxypropyl acrylate 1211 Indene 1212 Indium & compounds, as In 1213 Iodoform 1214 Iron oxide fume as fe (Fe203> 1215 Iron pentacarbonyl as Fe 1216 Iron salts, soluble, as Fe 1217 Isoamyl alcohol 1218 Isobutyl alcohol 1219 61788-32-7 999-61-1 95-13-6 7440-74-6 75-47-8 1309-37-1 13463-40-6 123-51-3 78-83-1 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table HI - Proposed PELs (NIOSH concurrence) IUC TWA STEL PEL PP C3 mg/m3 C 10 ppm mg/m3 PP mg/m3 3 10 C 10 C 10 10 11 C 3 C 2.5 3 0.5 5 0.5 3 10 45 0.1 0.6 10 5 None None None None None 10 0.1 0.8 0.2 1.6 None 1 None too 360 125 450 100 360 50 150 100 300 July 25. 1968 REL 4.7 ppm (5 mg /m3) cei1ing (10 min) 3 ppm (2.5 mg F/m3 ) TWA; 6 ppm (5.0 mg F/m3 ) ceiling (15 min) SL 061998 1 CHEH1CAL NAME HS NUMBER lsooctyl alcohol - Skin Isophorone Isophorone diisocyanate Sk in 1220 1221 1222 Isopropyl alcohol 1225 Isopropyl ether 1226 N-Isopropyl ani1ine - Skin 1229 Ketene 1231 Manganese, as Hn Fume 1236A Manganese cyclopentadienyl tricarbonyl, as Hn - Skin 1237 Mercury, as Hg - Skin Aryl & inorganic compounds 1240 Vapor 1241 Alkyl compounds 1242 Tabulation of N10SH Reviews <f Proposed PEI.s HIOH Table N1 - Proprsed PELs iN'OSII concurrent) CAS LUMBER _LLK_____ TWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 26952-21-6 50 270 None 78-59-1 C 5 C 25 25 140 4098-71-9 0.01 (NIC 0.005 0.09 0.045) None 67-63-0 400 980 500 1,225 400 980 108-20-3 250 1,050 310 1,320 500 2.100 768-52-5 2 10 Nr . 463-51-4 0.5 0.9 1.5 3 0.5 0.9 7439-96-5 1 3 15 July 25, I960 IfE L 4 ppm (23 mg/m-1) TWA 45 Pg/m3 (5 ppb) TWA, 180 Pg/m3 (20 ppb) cei1ing (10 min), Di isocyanates 400 ppm (984 mg/m3) TWA; 800 ppm (1,968 mg/m3) ceiling (15 min) 12079-65-1 7439-97-6 0.1 0.1 0.05 0.0) None 0.03 C 0.1 0.05 mg Hg/m3, 8-hr TWA C 0.1 0.05 mg Hg/*3. 8-hr TWA 0.01 (C 0.04) SL 061999 12 CHEHICAL NAME HS NUMBER CAS NUMBER Hethacrylic acid 1244 He thomy1 (Lannate) 1245 4-Hethox yphenol 1247 Hetfiyl 2-cyanoacrylate 1248 Methyl acetate 1249 Hethyl acetylene-propadiene Mixture (MAPP) 1250 Hethylacrylonitrile - Skin 1251 Methyl alcohol - Skin 1252 79-41-4 16752-77-5 150-76-5 137-05-3 79-20-9 126-98-7 67-56-1 Tabulation of NIOSH Reviews, of Proposed PELs HIOSH Table HI - Proposed PELs (HIOSH concurrence! ILV TWA STEL PCl pp *g/n3 ppM Mg/m3 ppM mg/m3 20 70 None 2.5 None 5 None 2 8 4 16 None 200 ' 610 250 760 200 610 1.000 l 200 1,800 3 260 1,250 2.250 250 310 1,000 None 200 1,800 260 Hethyl deMeton - Skin 1256 Hethyl ethyl ketone peroxide 1257 Hethyl formate 1258 Hethyl isoamyl ketone 1260 Methyl isobutyl carbinol Skin 1261 8022-00-2 1338-23-4 107-31-3 110-12-3 108-11-2 C 0.2 0.5 C 1.5 100 250 150 375 50 240 25 100 40 165 None None 100 None 25 250 100 REL 200 ppm (262 mg/m3) TWA; 800 pp (1,048 mg/m3) ceiling (15 min) 50 ppm (230 mg/m3) TWA SL 062000 CHEMICAL NAME HS NUMBER Methyl isopropyl ketone 1262 Methyl n-anyl ketone 1264 Methyl parathion - Skin 1265 Methyl silicate 1266 alpha-Methyl styrene 1267 Hethyliyt 1268 Methyl cyclohexanal 1269 o-Methylcyclohexanone - Skin 1270 2-Methylcydopentadienyl manganese tricarbonyl, as Hn - Skin 1271 Methylene bis(4-cyclohexylisocyanate) 1272 CAS NUMBER 563-80-4 110-43-0 298-00-0 681-04-5 98-83-9 108-87-2 25639-42-3 583-60-8 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table HI - Proposed PELs {NIOSH concurrence) TLV TWA STEL PEL PP mg/m^ ppm ppm g/m^ 200 705 None 50 235 100 465 0.2 None 16 None 50 240 100 485 C 100 C 480 400 1,600 500 2,000 50 235 100 470 50 230 75 345 100 460 12108-13-3 0.2 5124-30-1 C 0.01 (NIC 0.005 C 0.11 0.055) None None Hetribuzin Mica Honocrotophos 1275 1276 1279 21087-64-9 12001-25-2 6923-22-4 5 3, Respirable dust 3 0.25 None None July 25. 1988 REL 100 ppm (465 mg/m^l TWA 0.2 mg/m^ TWA 55 Pg/nr* TWA 210 Pg/rn-* Ceiling (10 min) SL 062001 14 CHEMICAL NAME KS NUMBER CAS NUMBER Monoaethylaniline - Skin (N-Hethyl aniline) Morpholine - Skin Naphthalene Nitric acid p-Nitroani1ine - Skin Nitrogen dioxide 1280 1281 1282 1286 1287 1269 100-61-8 110-91-8 91-20-3 7697-37-2 100-01-6 10102-44-0 Nitroglycerin (NG) - Skin 1290 55-63-0 Tabulation of N10SH Reviews of Proposed PELS NIOSH Table N1 - Proposed PELs (NIOSH concurrence) JUt TWA STEL PEL ppm ag/a3 ppm ag/a3 ppm mg/m3 0.5 2 29 20 10 2 0.05 3 70 50 5 3 6 30 105 20 70 15 75 10 50 4 10 2 5 16 5 10 C 5 C 9 0.05 0.5 C 0.2 C 2 Nitrotoluene - Skin Nonane Octachloronaphthalene - Skin Osmium tetroxide, as Os Oxalic acid Oxygen difluoride 1292 1293 1295 1298 1299 1300 99-08-1 111-84-2 2234-13-1 20816-12-0 144-62-7 7783-41-7 2 11 200 1,050 0.1 5 30 None 0.3 0.1 0.0002 C 0.05 0.002 1 C 0.1 0.0006 0.006 2 0.05 0.002 ' 0.1 July 25. 1988 REL 2 ppa (5 mg/m3) 1WA 1 ppm ( 1.8 <ng/m3) ceiling (15 min) 0.1 mg/m3 ceiling (20 min) recommended limit for either substance alone or mixtures SL 062002 15 CHEMICAL NAME HS NUMBER CAS NUMBER Paraffin wax fuae 1302 Paraquat, respirable sizes 1303 Pentaborane 1304 Perchloryl fluoride 1309 Phenothiazine - Skin 1313 Phenyl ether (vapor) 1314 Phenyl phosphine 1318 Phorate (Thinet) - Skin 1319 Phosdrin - Skin (Hevinphos) 1320 Phosphine 1321 Phosphoric acid 1322 Phosphorus oxychloride 1323 Phosphorus pentasulfide 1324 Phosphorus trichloride 1325 Phthalic anhydride 1326 8002-74-2 4685-14-7 19624-22-7 7616-94-6 92-84-2 101-84-8 638-21-1 298-02-2 7786-34-7 7803-51-2 7664-38-2 10025-87-3 1314-80-3 7719-12-2 05-44-9 Tabulation of MIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (N10SH concurrence) ILK. TWA STEL PP" ag/a3 PP" ag/a3 2 PEL PP" ag/a3 None 0.1 0.5 0.005 0.01 0.015 0.03 0.005 0.01 3 14 6 28 3 13.5 5 None 1 7 2 14 1 7 C 0.05 C 0.25 None 0.05 0.2 None 0.01 0.1 0.03 0.3 0.1 0.3 0.4 1 1 0.3 0.4 131 0.1 0.6 0.5 3 None 131 0.2 1.5 0.5 3 0.5 3 16 2 12 SL 062003 16 July 25. 1988 CHEMICAL NAME HS NUMBER CAS NUMBER m-Phthalodinitrile 1327 Picric acid - Skin 1329 Piperazine dihydrochloride 1330 PI atinum Hetal 1332 626-17-5 88-89-1 142-64-3 7440-06-4 Potassium hydroxide Propargyl alcohol - Skin Propionic acid Propoxur (Baygon) n-Propyl acetate Propyl alcohol - Skin n-Propyl nitrate Propylene glycol dinitrate - Skin Propylene glycol nonoaethyl ether 133d 1335 1336 1337 1338 1339 1340 1342 1343 1310-58-3 107-19-7 79-09-4 114-26-1 109-60-4 71-23-8 627-33-4 6423-43-4 107-98-2 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table Nl - Proposed PELs (NIOSH concurrence) TWA ppm mq/m? 5 0.1 5 ' C2 l2 10 30 0.5 200 840 200 500 25 105 STEL ppm mg/m^ 0.3 PEL pprt mg/m' None 0.1 None None None None 15 45 None None 250 1,050 200 840 250 625 200 500 40 170 25 105 0.05 100 0.3 360 150 540 None None SL 062004 17 July 25, 1968 CHEMICAL NAME Resorcinol Rhodiurn Metal and Insoluble compounds, as Rh Soluble salts, as Rh Ronnel HS NUMBER CAS NUMBER 1346 1347 1348 1349 108-46-3 7440-16-6 299-84-3 Tabulation of NIOSU (itviews ol Proposed PELs N10.` K TaVle *11 - Proposed PELS (NIOSf< concurrent) JUL TWA STEL PEL PP mg/nr* ppm mg/m-* PP mg/m-* 10 45 20 90 None 1 0.01 10 0.1 0.001 15 Silica -- Amorphous* Percipitated silica and silica gel Silicon tetrahydride 1353 1361 7803-62-5 5 10 7 None 6 Silver Metal, dust and fume 1362 7440-22-4 0.1 0.01 Soapstone Respirable dust 1363 3 Total dust 1363A 6 The value is for total dust containing no asbestos and <1% free silica. None 6 Sodium azide Sodium bisulfite 1364 1365 26628-22-8 7631-90-5 C 0.1 C 0.3 5 None None Sodium fluoroacetate - Skin 1366 62-74-8 0.05 0.15 0.05 SL 062005 18 July 25. 1988 REL CHEMICAL NAME Sodium hydroxide Sodium metabisulfite Stoddard solvent HS NUMBER CAS NUMBER 1367 1366 1371 13)0-73-2 7681-57-4 6052-41-3 Styrene, monomer 1372 100-42-5 Subtilisins 1373 1395-21-7 (Proteolytic enzymes as 100% pure crystalline enzyme) (k) Based on "high volume" sampling. Sulfur dioxide 1375 7446-09-5 Sulfur monochloride 1376 10025-67-9 Sulfur pentafluoride 1377 5714-22-7 Sulfur tetrafluoride 1378 7783-60-0 Sul fury) fluoride 1379 2699-79-8 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSH concurrence) ILV TWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 C2 2 5 None 100 525 500 2,900 50 215 100 425 100 ppm TWA, 200 ppm Ceiling, 600 ppm Max Ceiling, (5 min in 3 hr) C 0. 00006 (k) None July 25. 1988 REL 2mg/m3 ceiling (15 min) 350 mg/m3 TWA; 1,800 mg/m3 ceiling (15 min); Blood and urine monitoring required; action level: 350 mg/m3 TWA 50 ppm (213 mg/m3) TWA; 100 ppm (426 mg/m3) ceiling 2 C1 C 0.01 C 0.1 5 5 C6 C 0.1 C 0.4 20 5 10 to 40 5 1 0.025 None 5 13 6 0.25 20 0.5 ppm (1.3 mg/m3) TWA 062006 19 CHEMICAL NAME HS HUMBER CAS HUMBER Sul profos 1380 Talc (containing no asbestos 1381 fibers} Tantalum 1382 35400-43-2 14807-96-6 7440-25-7 Terphenyls 1384 Tetraethyl lead, as Pb Skin 1386 Tetrahydrofuran 1387 Tetramethyl lead, as Pb Skin 1388 Tetrasodium pyrophosphate 1389 Thioglycolic acid - Skin 1392 Thionyl chloride 1393 Tin Organic compounds, as Sn except SnH4, as Sn - Skin Metal, Oxide & inorganic compounds, as Sn 1394 1395 26140-60-3 78-00-2 109-99-9 75-74-1 7722-88-5 68-11-1 7719-09-7 7440-31-5 Tabulation of NTOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSH concurrence} XLV. TWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 1 None 2, Respirable dust 3 5 10 5 (NIC 10 no asbestos and <1% crystalline silica) C 0.5 C5 Cl C 9 0.1 0.075 200 590 250 735 200 590 0.15 0.075 5 14 C 1 C5 None None None 0.1 0.1 22 July 25, 1988 PEL 0.1 ng Sn/m3 TWA SL 062007 20 CHEMICAL NAME Toluene (toluol) HS NUMBER CAS NUMBER 1397 108-86-3 Tributyl phosphate l, 1 ,2-Trichloro-1,2,2- trifluoroethane Trichloroacetic acid 1,2,4-Trichlorobenzene Trinellitic anhydride 1402 126-73-8 1403 1404 1405 1409 76-13-1 76-03-9 120-82-1 552-30-7 Trinethyl phosphite 1410 Trinethylanine 141) Trinethyl benzene 1412 2,4,6-Trinitrotoluene (TNT) - Skin 1413 Triorthocresyl phosphate Skin 1414 Triphenyl anine 1415 121-45-9 75-50-3 25551-13-7 118-96-7 78-30-8 603-34-9 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N1 - Proposed PELs (NIOSH concurrence) 1VL TWA STEL PEL pp ng/n3 ppm ng/n3 ppa *g/n3 100 375 150 560 200 ppn THA, 300 ppn Ceiling, 500 ppn Man Ceiling (10 min) 0.2 2.5 5 July 26, I960 REL 100 ppn (375 ng/n3), 8-hr TWA; 200 ppn (750 ng/n3) ceiling (10 min) 1.000 1 C5 0.005 7,600 7 C 40 0.04 1,250 9,500 1,000 None None None 7,600 2 10 None 10 24 15 36 None 25 125 None 0.5 1.5 Should be handled in Lhe workplace as an extremely toxic substance 0.1 0.1 5 None SL 062008 21 CHEMICAL NAME Tungsten, as W Insoluble compounds Soluble compounds n-Valeraldehyde Vinyl toluene VH & P Naphtha HS NUMBER CAS NUMBER 1416 1417 1420 1427 1429 7440-33-7 110-62-3 25013-15-4 8030-30-6 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table Nt - Proposed PELs (NIOSH concurrence) lilt TWA STEL PEL ppm mg/m* ppm mg/m* ppm mg/m-* 5 10 None l 3 None 50 175 None 50 240 100 485 100 480 300 1,350 None Xylene (o-, m-, p-isomers) 1431 1330-20-7 100 435 150 655 100 435 m-Xylene alpha, alpha'diamine - Skin Xylidine - Skin Zinc chloride fume Zinc oxide fume 1432 1433 143S 1437 1477-55-0 1300-73-8 7646-86-7 1314-13-2 2 C 0.1 10 1 5 None 5 25 21 10 5 July 25. I960 REL 5 mg W/m* TWA; 1 mg W/m* TWA; 350 rng/m* TWA 1,800 mg/m* ceiling (15 min) Blood and urine monitoring required; action level; 200 mg/m* TWA 100 ppm (434 mg/*r*) TWA; 200 ppm (868 mg/m*) ceiling (10 min) 5 mg/m* TWA; 15 mg/m* ceiling (15 min) SL 062009 22 July 25. 1988 Tabulalion of NIOSH Reviews of Proposed PELs NIOSH Table N2 - Proposed PELs (NIOSH non-concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER TLV TWA STEL ppm mg/m-* ppm mg/m^ PEL ppm mg/a-* REL Acrylic acid 1009 n-Butyl glycidyl ether (BGE) 1052 79-10-7 10 (NIC 2 2426-08-6 25 30 6) 135 None 50 270 4.4 ppm (30 mg/av*) ceiling (15 min) Camphor, synthetic 1063 76-22-2 2 . 12 3 18 0.3 2 Caprolactam Vapor Coal dust <5X quartz >5X quartz Disulfoton Ethyl bromide Ethyl ether Ethylene glycol vapor fenthion - Skin Fluorine 1065 1096 1097 1152 1163 1164 1169 1175 1179 105-60-2 5 (NIC 0.25 298-04-4 74-96-4 60-29-7 107-21-1 55-38-9 7782-41-4 200 400 C 50 l 20 10 40 1) 2, Respirable fraction 0.1 Respirable quartz 0.1 890 250 1,110 1,200 500 1.500 C 125 0.2 2 24 None None 200 400 None None 0.1 2.4 10*(i02+2> 890 1,200 0.2 SL 062010 1 CHEMICAL NAME Formanide (NIC - skin) Furfural - Skin Heptane (n-Heptane) Tabulation of NIOSi! Reviews if Proposed PELs NIO >11 Table M2 - Proposed PELs (N105H non-concurr*nce) HS NUMBER 1182 1183 1194 CAS I.UMBER 75-12-7 (NIC 98-01-1 142-82-5 THA ppm mg/m^ 20 30 10 15) 28 400 1,600 STEL ppm mg/n-* 30 45 PEL ppm mg/m^ None 5 500 2,000 500 20 2,000 Hexane isomers 1201 500 1,800 1,000 3,600 2-Hexanone (Methyl n-butyl ketone) Isopropoxyethanol Isopropyl acetate 1202 1223 1224 591-78-6 109-59-1 108-21-4 5 20 100 410 25 105 None 250 950 310 1,185 250 950 July 25. 1968 REL 85 ppm (350 ng/m^) TWA; (Mixtures not to exceed 350 mg/tr* TWA); 440 ppm (1,800 mg/m^) ceiling (15 min) singly or mixtures; Action level set at 200 mg/*3 for C5-C8 alkanes 100 ppm (350 mg/m^) TWA; (Mixtures not to exceed 350 mg/m* TWA); 510 ppm (1,800 mg/m^) ceiling (15 min) singly or mixtures; Action level set at 200 ng/m^ for C5-C8 alkanes 1 ppm (4 mg/m^) TWA SL 062011 2 CHEMICAL NAME Isopropylamine Manganese tetroxide Mesityl oxide Octane HS NUMBER CAS NUMBER 1228 1238 1243 1296 75-31-0 1317-35-7 141-79-7 111-65-9 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table fi2 - Proposed PELs (NIOSH non-concurrence) 111i TWA STEL PEL ppt mg/mJ ppa mq/m^ ppa mg/m^ 5 12 10 24 5 12 1 None 15 60 25 100 25 100 300 1,450 375 1 .800 500 2.350 Ozone Pentane 1301 1306 10028-15-6 0.1 (NIC C 0.1 109-66-0 600 0.2 C 0.2) 1,800 0.3 750 0.6 0.1 0.2 2.250 1,000 2.950 2-Pentanone (Methyl propyl ketone) 1307 107-87-9 200 700 250 875 200 700 July 25. 1466 REL 10 ppm (40 mg/r*) TWA 75 ppm (350 mg/m^) TWA; (Mixtures not to exceed 350 mg/m^ TWA); 385 ppm (1,800 mg/m^) ceiling (15 min) singly or mixtures; Action level set at 200 mg/m^ for C5-C8 alkanes 120 ppm (350 mg/m^) TWA; (Mixtures not to exceed 350 mg/m^ TWA); 610 ppm (1,800 mg/m^) ceiling (15 min) singly or mixtures; Action level set at 200 mg/m^ for C5-C8 alkanes 150 ppm (530 aig/m^) TWA 062012 3 CHEMICAL NAME HS NUMBER CAS NUMBER Silica -- Amorphous* Oiatomaceous earth (uncalcined) m-Toluidine - Skin Triethylamine Vinyl acetate 1352 1401 1408 1424 68855-54-9 108-44-1 121-44-8 108-05-4 Zirconium compounds, as Zr 1439 7440-67-2 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N2 - Proposed PELs (NIOSH non-concurrence) IUL TWA STEL PEL ppm mg/m-* ppm mg/m3 ppm mg/m3 10 6 29 None 10 40 15 60 25 100 10 30 20 60 None 5 10 5 July 25, 1988 REL 4 ppm (15 mg/m3) ceiling (15 min) SL 062013 4 CHEMICAL NAME HS NUMBER 2-Aminopy ridine n-Amyl acetate sec-Amyl acetate Antimony & compounds, as Sb Antimony trioxide Handling and use, as Sb ANTU Azinphos-methyl - Skin Barium, soluble compounds, as Ba Benzoyl peroxide Biphenyl Boron trifluoride Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N3A - Establ ished PELs Not Addressed in Current Rulemaking (NIOSH concurrence) CAS NUMBER TLV TWA SIEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 504-29-0 0.5 2 0.5 2 628-63-7 100 530 100 525 626-38-0 125 665 125 650 7440-36-0 0.5 0.5 1309-64-4 0.5 None 86-88-4 0.3 0.3 86-50-0 0.2 0.2 7440-39-3 0.5 0.5 94-36-0 5 92-52-4 0.2 1.5 7637-07-2 C 1 C 3 5 0.2 1.5 C 1 C3 Bromoform - Skin sec-Butyl acetate 75-25-2 105-46-4 0.5 5 200 950 0.5 5 200 950 July 25. 1988 REL 0.5 mg Sb/m3 TUA 0.5 mg Sb/m3 TWA 5 mg/m3 TWA No exposure limit recommended due to the absence of a reliable monitoring method SL 062014 1 CHEMICAL NAME tert-Butyl acetate Butyl amine - Skin Carbary! HS NUMBER Tabulation of NIOSH Reviews of Proposed PELs t 10SH Table N3A - Established PELs Hot Addressed in Current Rulemaking (NIOSH concurrence) CAS NUMBER _Ii______ IWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m3 540-88-5 200 950 200 950 109-73-9 C 5 C 15 C 5 C 15 63-25-2 5 5 Chlorinated diphenyl oxide Chlorine trifluoride Chloroacetaldehyde alpha-Chloroace tophenone Chi orobromomethane Chloropicrin Chromium (II) compounds, Cr (Soluble) Chromium (III) compounds, Cr (Soluble) Copper Dusts ft mists, as Cu Crotonaldehyde 55720-99-5 7790-91-2 107-20-0 532-27-4 74-97-5 76-06-2 7440-50-8 4170-30-3 C 0.1 C1 0.05 200 0.1 0.5 C 0.4 C3 0.3 1,050 0.7 250 0.3 2 1.300 2 C 0. 1 C1 0.05 200 0.1 0.5 C 0.4 C3 0.3 1,050 0.7 0.5 0.5 0.5 0.5 1 27 1 2 July 25. 1988 KEL 5 mg/m* (HA reproductive effects; minimum exposure during pregnancy SL 062015 2 Tabulation of NIOSH Reviews of Proposed PELs ft [OSH Table N3A - Established PELs Not Addressed in Current Rulemaking (NIOSH concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER Cumene - Skin Cyclohexane Cyciohexene Cyclopentadiene 2,4-0 Demeton - Skin Diacetone alcohol Diazomethane Oiborane Dibutyl phthalate o-Di chiorobenzene Dichlorodif1uoromethane 1,2-Dichloroethylene Oichiorotet raf1uoroethane Oichlorvos - Skin 98-82-8 1i0-82-7 ) 10-83-8 542-92-7 94-75-7 B065-48-3 123-42-2 334-88-3 19287-45-7 84-74-2 95-50-1 75-71-8 540-59-0 76-14-2 62-73-7 TWA ppm mg/m^ 50 245 300 1,050 300 1,015 75 200 10 0.01 0.1 50 240 0.2 0.4 0.1 0.1 5 C 50 300 1.000 4,950 200 790 1.000 7,000 0.1 1 SEEL 1 ppm mg/m PEL 3 ppm mg/mJ 50 245 300 1,050 300 1 ,015 75 200 10 0.1 50 240 0.1 0.4 0.1 0.1 5 C 50 C 300 1,000 200 4,950 790 1,000 7,000 1 July 25. 1988 REL 50 ppm (240 mg/m*) TWA SL 062016 3 CHEMICAL NAME HS NUMBER 2-Diethyl ami noethanol - Ski Di f1uorodibromomethane Diisopropylamine - Skin Oimethyl acetamide - Skin Dimethyl amine Dimethylformamide - Skin Dimethylphthalate Dinitro-o-cresol - Skin Oinitrobenzene (all isomers) - Skin Endrin - Skin EPN - Skin Ethyl acetate Ethyl alcohol Ethyl amyl ketone Tabulation nf NIOSII Reviews if Proposed PELs OSH Table N3A - Estab 'shed Ills Not Adrressed in Current 1ulemakiug INIGSH concurrent) CAS HUMBER TLV TWA SIEL PEL ppm mg/m-* ppm mg/m3 ppm mg/m3 10D-37-8 10 50 10 50 75-61-6 100 860 100 860 108-18-9 5 20 5 20 127-19-6 10 35 10 35 124-40-3 10 10 to 18 60-12-2 10 30 10 30 131-11-3 5 5 534-52-1 0.2 0.2 528-29-0; 99-65-0; 100-25-4; 25154-54-5 0.15 l 1 72-20-8 0.1 0.1 2104-64-5 0.5 0.5 141-78-6 400 1,400 400 1,400 64-17-5 1,000 1,900 1,000 1,900 541-05-5 25 130 25 130 JEL 0.2 mg/m3 TWA SL 062017 4 CHEMICAL NAME Ethyl amine Ethyl butyl ketone Ethylenediamine Ethyl formate Fluorides. as F Formic acid Hafnium Hexachloronaphthalene sec-Hexyl acetate Hydrogen chloride Hydrogen peroxide Hydrogen selenide, as Se Iodine Isoamyl acetate Isobutyl acetate HS NUMBER Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N3A - Established PELs Not Addressed in Current Rulemaking (NIOSH concurrence) CAS NUMBER Hi TWA STEL PEL 75-04-7 PP* 10 mg/u* 18 ppm mg/m^ ppm mg/m-* 10 18 106-35-4 50 230 50 230 107-15-3 109-94-4 10 25 100 300 10 25 too 300 2.5 2.5 64-18-6 5 9 59 7440-58-6 0.5 0.5 1335-87-1 0.2 0.2 108-84-9 50 300 50 300 7647-01-0 C 5 C 7 C5 C 7 7722-84-1 7783-07-5 I 0.05 1.5 0.2 ' 1.4 0.05 0.2 7553-56-2 123-92-2 110-19-0 C 0.1 100 150 C1 525 700 187 875 C 0.1 too too C1 525 750 SL 062018 5 REL 2.5 mg E/nr* TWA CHEMICAL NAME MS Lindane - Skin Lithium hydride L. P.u. i. , .4. petr. gas) Haleic anhydride Hethyl acetylene Hethyl acrylate - Skin Hethylal Hethylamine Methylene C . ,.iittiy1 isocyanate (Uiphenylmethane diisocyanate; MDI) Tabulation of NIOSH Reviews of Proposed PELs NlOSH Table N3A - Established PELs Not Addressed in Current Rulemaking (NIOSH concurrence) CAS NJMBER ILK IMA S1EL PEL ppm mg/m* ppm mg/m^ ppm mg/m-* 58-09-9 0.5 0.5 7580-67-8 0.025 0.025 68476-85-7 1.000 1,800 1,000 1,800 108-3)-6 0.25 1 0.25 1 74-99-7 1,000 1,650 1,250 2,040 1,000 1,650 96-33-3 10 35 10 35 109-87-5 74-89-5 ),000 3,100 12 1,000 10 3.100 12 101-68-8 C 0.02 C 0.2 0.02 0.2 Hethyl isocyanate - Skin Hethyl methacrylate Ni ckel Hetal Nicotine - Skin Nitrie oxide 624-83-9 00-62-6 7440-02-0 54-11-5 10102-43-9 0.02 too 25 0.05 410 1 0.5 30 0.02 100 25 0.05 410 1 0.5 30 July 25, 1988 REL 50 Pg/m* (5 ppb) TWA, 200 Pg/m* (20 ppb) ceiling (10 min). 25 ppm (30 mg/m*) IWA SL 062019 6 CHEMICAL NAME HS NUMBER Nitrobemene - Skin Ni troethane Ni trogen trifluoride l-Nitropropane Pentachloronaphthalene Pentachlorophenol - Skin Pe rc hi o route thyl mercaptan p-Phenylene diamine - Skin Phosphorus (yellow) Phosphorus pentachloride Pindone Platinum Soluble salts, as Pt Propane Pyrethrum Pyridine Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N3A - Established PELs Not Addressed in Current Rulemaking (NIOSH concurrence) CAS NUMBER USL TMA SIEL PEL ppm g/mJ ppm mg/m^ ppm mg/m^ 98-95-3 1 5 15 79-24-3 100 310 100 310 7783-54-2 10 30 10 29 108-03-2 25. 90 25 90 1321-64-8 0.5 0.5 87-86-5 0.5 0.5 594-42-3 0.1 0.8 0.1 0.8 106-50-3 0.1 0.1 7723-14-0 0.1 0.1 10026-13-8 0.) 1 1 83-26-1 0.1 None 7440-06-4 74-98-6 8003-34-7 110-86-1 0.002 E (Si ngle asphyxiant) 5 5 15 1,000 5 0.002 1,800 5 15 SL 062020 7 Tabulation of NIOSH Reviews of Proposed PELs i 10SH Table N3A - Established PELs Not Addressed in Current Rulemaking (NIOSH concurrence} CHEMICAL NAME HS NUMBER CAS NUMBER Quinone Rotenone (commercial) Selenium compounds, as Se Selenium hexafluoride, Se Silver Soluble compounds, as Ag St ibine Strychnine Sulfotep - Skin Sulfur hexafluoride Sulfuric acid 2,4,5-T Tellurium A compounds, Te Tellurium hexafluoride, Te IEPP - Skin 1,1,1,2-Tetrachloro-2,2- difluoroethane 106--51--4 03-79-4 7782-49-2 7783-79-1 7440-22-4 7803-52-3 57-24-9 3689-24-5 2551-62-4 7664-93-9 93-76-5 13494-80-9 7783-80-4 107-49-3 76-11-9 TWA ppm mg/m3 0.1 0.4 5 0.2 0.06 0.2 0.1 1,000 0.02 0.004 0.01 0.5 0.15 0.2 6,000 1 10 0.1 0.2 0.05 500 4,170 STEL ppm mg/m3 PEL ppm mg/m3 0.1 0.4 5 0.2 0.06 0.4 0.1 1,000 0.02 0.01 0.5 0.15 0.2 6,000 1 10 0.1 0.2 0.05 500 4,170 July 26, 1980 REL 1 mg/m1 TWA Ob^021 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N3A - Established PFLs Not Addressed in Current Rulemaking (NIOSH concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER JUL TWA STEL mg/J ppm ng/ PEL ppm mg/mJ 1,1,2,2-Tetrochloro-l,2dit1uoroethane 76-12-0 500 4,170 500 4,170 Tetrachloronaphthalene 1335-88-2 2 2 Tetramethyl succinoni t ri le 3333-52-6 0.5 3 0.5 3 Tetran itcomethane Tetryl - Skin Thallium Soluble compounds, as T1 Thiram Trichloronaphthalene T rif1uorobromomethane Triphenyl phosphate Turpentine 062022 SL 509-14-8 479-45-8 7440-28-0 137-26-8 1321-65-9 75-63-8 1 15-86-6 8006-64-2 18 1.5 1,000 100 0.1 5 5 6,100 3 560 9 1a 1.5 0.1 5 5 1,000 6,100 3 100 560 July 25, 1988 REL 1 ppm (6 mg/nr*) ceiling (15 min); When present as mixtures or with other sources of cyanide, exposure to be considered additive and environmental limit to be calculated CHEMICAL NAME Warfarin Yttrium Tabulation ot KIOSK Reviews of Proposed PLs OSH Table N3A - Estabnshid T'lLs Not Adi'ressed in Current tulenaking (NIOSH toncurrene) HS NUMBER CAS iMUHBER _IUL TWA STEL ng/*J ppm mg/m1 PEL ppa mg/m1 81-81-2 0.1 0.1 7440-65-5 1 3 1 3EL SL 062023 10 CHEMICAL NAHE HS NUMBER Acetylene tetrabromide Chlorobenzene Chromium (II) compounds, Cr {Insoluble) Chromium (III) compounds, Cr (Insoluble) Cresol. all isomers - Skin Manganese dust & compounds Molybdenum, as Mo Soluble compounds Nitromethane Parathion - Skin Tabulation of NIOSH Reviews of Proposed PELs MOSh Table N3B - Established PELs Not Addressed in Current Rulemaking (NIOSH non-concurrence) CAS NUMBER Hit TWA STEL PEL ppm mg/m~* ppm mg/m^ ppm mg/m 79-27-6 1 15 1 15 108-90-7 75 350 75 350 0.5 1 .0 1319-77-3 7439-96-5 7439-98-7 75-52-5 56-38-2 0.5 5 22 C5 (NIC 5) 5 100 250 0.1 1.0 5 22 C5 5 100 250 0.1 July 25, 1988 REL 2.3 ppm (10 mg/m^) 0.05 mg/m^ TWA SL 062024 1 CHEMICAL NAME HS NUMBER CAS NUMBER Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N4 - Nuisance Dusts TLV TWA SIEL PEL ppm mg/er ppm mg/m^ ppm mg/m^ alpha-Alumina* 1014 1344-28-1 10 A1uminum Heidi & oxide Anhimi i um sul Idflidle 1016 1024 7429-90-5 7773-06-0 10 10 Barium sulfate* 1011 Benomyl 1012 Bismuth telluride (undoped) 1035 Boron oxide 1039 Calcium carbonate* 1057 Calcium sil icate* 1061 Calcium sulfate* 1062 7724-43-7 17804-35-2 1304-82-1 1303-86-2 1317-65-3 1344-95-2 7778-10-9 10 10 10 10 10 10 10 Cellulose (paper fiber)" 1076 9004-34-6 10 2-Chloro-6-trichloromethyl pyridine (Nitrapyrin) 1082 1929-82-4 10 20 *Tbe value is for total dust containing no asbestos and <1% free silica Ihe proposed table number that NIOSH has assigned based on an evaluation of the health effects "**NIOSH has not evaluated these chemicals in-depth 15 15 15 15 15 15 15 15 15 15 15 15 SL 062025 July 25. 1988 PROPOSED REE TABLE NUMBER* N2 KM* N1 mm* N2 ARM N1 m*m m*m m m DM Nl CHEMICAL NAME Clopidol Crag Herbicide (Sesone) Di cyclopentadienyl iron Eme r y" Ferbam fibrous glass dust HS NUMBER CAS NUMBER 1095 1102 1133 1155 1176 1178 2971-90-6 136-78-7 102-54-5 112-62-9 14484-64-1 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N4 - Nuisance Dusts TLV TWA STEL PEL ppm mg/m3 ppm mg/m3 ppm mg/m* 10 20 > 15 10 15 10 15 10 15 10 15 10 Nuisance dust PEL applies. 15 mg/m3 total dust; 5 mg/m* respirable fraction Glycerin (mist)* 1188 56-81-5 10 Graphite (synthetic)* 1191A 10 Gyp. 1192 see HS #1062 Kaolin* 1230 10 Limestone* 1232 see HS #1057 Magnesite* 1233 546-93-0 10 *Ihe value is for total dust contain ing no asbestos and (IX free silica "(he proposed table number that NIOSH has assigned based on an evaluation of the health effects **'mOSH has not evaluated these chemicals in-depth 2 SL 062026 15 15 15 15 July 25. 1966 PROPOSED REL TABLE NUMBER** N1 N1 N) N2 N1 3 million fibers/ m* 1WA (fibers <3.5 Pm diameter and >10 Mm length); 5 mg/m* TWA (total fibrous glass) N6B N2 N2 ft* a *mm mmm ... CHEMICAL NAME HS NUMBER CAS HUMBER Tabulation of NIOSH Reviews of Proposed PECs N10SH Table N4 - Nuisance Dusts HV TWA STEL 7 ppm mg/m ppm mg/m^ PEL ppm mg/m^ Magnesium oxide fume 1234 1309-48-4 10 Malathion - Skin 123S 121-75-5 to Marble* Melhoxychlor Mineral wool fiber' 1239 1246 1277 see HS #1057 72-43-5 10 10 Molybdenum, as Mo Insoluble compounds Nuisance particulates" 1278 1294 7439-98-7 10 10 Oil mist, mineral (excluding vapor) Pentaerythritol* Perlite* Picloram (Tordom) Plaster of Paris* 1297 1305 1310 1328 1331 8012-95-1 115-77-5 1918-02-1 see HS #1062 5 10 10 10 10 20 *The value is for total dust containing no asbestos and <1X free silica "*The proposed table number that NIOSH has assigned based on an evaluation of the health effects "*N10SH has not evaluated these chemicals in-depth tSee testimony 15 15 15 15 15 15 5 15 15 SL 062027 3 July 25, 1988 PROPOSED RCL 1 ABLE 15 mg/m * TWA N2 N1 N* N6A N6B N2 t Nl HA* AH N2 AHA CHEMICAL NAME MS NUMBER CAS NUMBER Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N4 - Nuisance Ousts THA TtV STEL ppm mg/m-*** ppm mg/m3 PEL ppm mg/m3 Portland cement* 1333 65997-15-1 Rouge* 1361 Sil icon* 1359 7440-21-3 Si 1icon ..uide* 1360 409-21-2 Starch* 1369 9005-25-8 Sucrose* 1374 57-50-1 Temephos (abate) 1383 3303-96-8 4,4' >ert- buty l-iii-c resol) 1391 96-69-5 Titanium dioxide* 1396 13463-67-7 Vegetable oil mists* 1423 (except castor oi1. cashew nut, or similar irritant oils) Zinc stearate* 1434 557-05-1 Zinc oxide dust* 1438 1314-13-2 10 10 10 10 10 10 10 10 10 10 10 10 15 15 15 15 15 15 15 15 15 15 15 5 *The value is for total dust containing no asbestos and <1% free silica **The proposed table number that NIOSH has assigned based on an evaluation of the health effects --NIOSH has not evaluated these chemicals in-depth SL 062028 4 July 26. 1986 PROPOSED REL TABLE NUMBER' 5 mg ZnO/m3 TWA; 15 mg ZnO/m3 ceiling (15 min) M*M N2 mm aia Ml N1 Nt N1 N6B N1 N1 N2 CHER1CAT N\HE Acetone cyanohydrin Acet ylene Adiponitrtle n-Butyronitri le Cetylmercaptan HS NUMBER Tabulation of NUJSH Reviews of Proposed PELs NIOSH Table N5 - Nil SH R'Ls not Included ir. OSHA Rulemali uj CAS .UMBER TLV TWA MET ppm ng/m-* ppm mg/m3 PEL ppm mg/m3 75-86-5 None None 74-86-2 E (simple asphyxiant! None 111-69-3 None None 109-74-0 None None 2917-26-2 None None Cyclohexylmercaptan 1569-69-3 None None Decylmereaptan 143-10-2 None None 2,4-Diaminoanisole o-Dianisidine - based dyes 615-05-4 various None None None None July 25. 1986 'EL l ppm (4 mg/m3) ceiling (15 mini, Nitriles No exposure >2,500 ppm (2,662 mg/m3) 4 ppm (IB mg/m3) TWA Nitriles 8 ppm (22 mg/m3) TWA Ni tri 1 es 1-Hexadecanethiol: 0.5 ppm (5.3 mg/m3) Ceiling (15 min) Cyclohexanethiol: 0.5 ppm (2.4 mg/m3) Ceiling (15 min) 1-Decanethiol: 0.5 ppm (3.6 mg/m3) Ceiling (15 mm) Ca; reduce exposure to lowest feasible level Ca; should be handled in the workplace with caution; exposure should be minimized 062029 1 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N5 - NIOSH RLs not Included in OSHA Rulemaking CHEMICAL NAME HS NUMBER CAS NUMBER liV TWA STEL -------------------------------- ------------------------ppm mg/rn^ ppm mg/m^ PEL --------------------------ppm mg/m^ bis(2-0imethyl aminoethyl Jether 3033-62-3 None None Dimethy1 ami nopropionitrile 1738-25-6 None None Oodecylmercaptan 112-55-0 None None Enflurane 13838-16-9 None None Ethylene thiourea 96-45-7 None None Eluroxene Glycolonitrile Halothane n-Heptylmercaptan 406-90-6 107-16-4 151-67-7 1639-09-4 None None None None None None None None July 25. 1088 REL ------------------ Exposure be minimized to NIAX Catalyst ESN Exposure be minimized to NIAX Catalyst ESN 1-Uodecanethiol: 0.5 ppm {4.1 mg/m^) Ceiling (15 mm) 2 ppm (15.1 mg/m-*) Cei1ing (1 hr) Waste Anesthetic Gases Ca; should be used in encapsulated form in industr1 worker exposure be minimized 2 ppm (10.3 mg/m^) Ceiling (1 hr) 2 ppm (5 mg/m-*) Ceiling (15 min), Nitriles 2 ppm (16.2 mg/m-*) Ceiling (1 hr) 1-Heptanethiol: 0.5 ppm (2.7 mg/m*) Ceiling (15 min) 2L 062030 2 CHEMICAL NAME HS NUMBER Hexamethylene diisocyanate (HOI) Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table NS - NIOSH RELs not Included in OSHA Rulemaking CAS f UMBER JiV__________________ TWA STEL ppm mg/m3 ppm mg/m3 PEL ppm mg/m3 822-06-0 None None n-Hexylmercaptan 111-31-9 None None Isobutyronitrile Kepone Kerosene Malononitri1e Hethoxyflurane Naphthalene diisocyanate (NOD 2-Nitro-naphthalene 78-82-0 143-50-0 8008-20-6 109-77-3 76-38-0 25551-28-4 None None None None None None 501-89-5 None None None None None None None None July 25, 1988 PEL 35 Pg/m3 TWA. 140 Pg/m3 Ceiling (10 min). Diisocyanate 1-Hexanethiol : 0.5 ppm (2.4 mg/m3) Ceiling (15 min) 6 ppm (22 mg/m3) TWA; Nitriles Ca; 1 Pg/m3 TWA 100 mg/m3 TWA Refined Petroleum Solvents 3 ppm (B mg/m3) TWA Nitriles 2 ppm; (13.5 mg/m3) Ceiling U hr) 40 Pg/m3 TWA, 170 Pg/m3 Ceil Ing, (10 min) Oiisocyanate Ca; reduce exposure to lowest feasible level SL 062031 3 CHEMICAL NAME Nitrous oxide n-Nonylmercaptan Ocladecylmercaptan n-Octylmereaptan Pentachloroethane Pentylmercaptan Propioni tri le n-Propylmercaptan HS NUMBER Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N5 - NIOSH RELs not Included in OSHA Rulemaking CAS NUMBER Hi TWA STEL PEL ppm mg/m^ ppm mg/m^ ppm mg/m^ 10024-97-2 None None 1455-21-6 None None 2885-00-9 None None 111-68-6 None None 76-01-70 None None 110-66-7 None None 107-12-0 107-03-9 None None None None July 25, 1988 REE 25 ppm TWA 1-Nonanethiol: 0.5 ppm (3.3 mg/m^) Ceiling (15 mm) 1-Octadecanethiol; 0.5 ppm (5.9 mg/m*) Ceiling (15 min) l-0ctanethiol: 0.5 ppm (3.0 mg/m-*) Ceiling (15 min) To be handled with caution in the workplace due to similaril to carcinogenic chloroethanes 1-Pentanethiol: 0.5 ppm (2.1 mg/nr*) Ceiling (15 min) 6 ppm (14 mg/m*) IWA Nitriles 1-Propanelhiol : 0.5 ppm (1.6 mg/m~*> Ceiling (15 min) SL 062032 4 CHEMiCAt NAME Succinonitrile HS NUMBER Tabulation of NIOSH Reviews of Proposed PELs N10SH fable H5 - NIOSH REls not Included in OSHA Rulenaiing CAS fUMBER m. IWA STEL ppm mg/er1 ppm mg/m-* PEL *1 ppm g/m 110-61-2 None None 2,3,7,8-Tetrachlorodibeniop-dioxin (ICDD) 1,1,1 ,2-Ielrachloroethane 1746-01-6 630-20-6 None None None None o-lolidine based dyes various None None 1-ilndecanethi ol 5332-52-5 None None Vinyl fluoride 75-02-5 None None Vinylidene fluoride 75-38-7 None None July 25. 1988 TEL 6 ppm (20 mg/m1) TWA Nitriles Ca; reduce exposure to lowest feasible level To be handled in the workplace with caution due to similarity to carcinogenic Chloroethane Ca; should be handled in the workplace with caution; minimize exposures Undecanethio): 0.5 ppm (3.9 mg/m') Ceiling (15 min) 1 ppm TWA, 5 ppm Ceiling to be controlled as specified lor vinyl chloride in 29 CfR 1910.1017 1 ppm fWA 5 ppm Ceiling (15 min) to be controlled as specified for vinyl chloride in 29 OR 1910.1011 062033 5 July 25. 1988 CHEHICAL NAME Acrylamide - Skin Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N6A - Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen (NIOSH concurrence! HS NUMBER CAS NUMBER 1008 79-06-1 TLV TWA STEL ppm mg/m-* ppm mg/m-* 0.03.A2 PEL ppm mg/in'* 0.3 KEL 0.3 mg/nr* 1WA Amit rol e (j-Amino-l2,4-triazo}e) 1020 Aniline & homologues - Skin 1025 Captafol - Skin 1066 Caplan 1067 Carbon tetrachloride - Skin 1073 61-82-5 62-53-3 2425-06-1 133-06-2 56-23-5 Chloroform 1066 67-66-3 Di-sec-octyl phthalate 1116 117-81-7 Dichloroacetylene 1123 Dichloroethyl ether - Skin 1127 Oichloropropene -Skin 1129 7572-29-4 H1-44-4 542-75-6 0.2 None 2 5.A2 10 0.1 5 30. A2 10. A2 50. A2 5 C 0.1 5 1 C 0.4 30 5 10 10 60 5 19 None None 10 ppm TWA, 25 ppm Ceiling, 200 ppm Max Ceiling C 50 C 240 5 None C 15 None C 90 2 ppm (12.6 mg/ir*) ceiling 45 liter sample (60 min} 2 ppm (9.78 mg/nr*) ceiling 45 liter sample (60 min} Reduce exposure to lowest feasible level SL 062034 I July 25. 1988 SI OSH Table N6A tabulation rf N10SH Reviews of Proposed PELs Proposed PELs that Hot tne OSItA Definition of "Potenlia' (NiOSK concurren e) Occupational Carcinogen CHEMICAL MANE HS NUMBER CAS NUMBER -ILSL. _ TWA STEL ppm mg/m* ppm mg/m-* PEL ppm mg/m-* REL Diglycidyl ether <DGEj 1139 2238-07-5 0.1 0.5 C 0.5 C 2.8 0.2 ppm (1 g/m*) cei1ing (15 min) Dimethyl sulfate - Skin 1142 77-78-1 0.1.A2 0.5.A2 15 Dioxane - Skin 114S 123-91-1 25 * 90 100 360 1 ppm (3.6 mg/m-*) ceiling (30 min) Ethylene dichloride 1168 107-06-2 10 40 50 ppm TWA. 100 ppm Ceiling. 200 ppm Max Ceiling (5 min in 3 hr) 1 ppm (4 mg/m*) TWA; 2 ppm (8 mg/m*) ceiling (15 min) Hexachlorobutadiene -Skin 1195 87-68-3 0.02.A2 0.24.A2 None Hexachloroethane - Skin 1197 67-72-1 10 (NIC 1 100 10) 1 to Reduce exposure to lowest feasible level Methyl iodide - Skin 1259 74-88-4 2.A2 10. A2 5 28 Exposure to methyl iodide should be reduced to the lowest feasible level SL 062035 2 CHEMICAL NAME Nickel carbonyl, as Ni Silica -- Crystal 1ine Cristobalite Tridymite Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N6A - Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen" (NIOSH concurrence! July 25. 1988 r *- HS NUMBER CAS NUMBER TLV TWA STEL ppm mg/m3 ppm mg/m3 PEL ppm mg/m3 REL 1284 13463-39-3 0.05 0.35 0.001 0.007 1 ppb (7 Hg/m3) TWA (lowest detectable level) 1354 1356 14464-46-1 15468-32-3 0.05, Respirable dust 0.05, Respirable dust 5DXSi02*2) Respirable dust 5^(XSi02*2) Respirable dust 50 Pg/m3 TWA, respirable free silica 1,1,2,2-Tetrachloroethane - 1385 Skin Toluene-2,4-diisocyanate (TDI) 1398 79-34-5 584-84-9 o-Toluidine - Skin Trichloroethylene 1399 1406 95-53-4 79-01-6 1,2,3-Trichloropropane Skin 1407 96-18-4 1 0.005 2.A2 50 10.A2 7 0.04 9.A2 270 60. A2 0.02 200 0.15 1,080 5 35 0.02 0.14 Reduce exposure to lowest feasible level Toluene diisocyanate (TDI): 35 Pg/m3 (5 ppb) TWA, 140 Pg/m3 (20 ppb) ceiling (10 min) 5 22 100 ppm TWA, 200 ppm Ceiling, 300 ppm Max Ceiling, (5 min in 2 hr) 25 ppm TWA 50 300 SL 062036 3 July 25. 19B8 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N6A Proposed PELs That Heet the OSHA Definition of "Potential Occupational Carcinogen (NIOSH concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER ___________ ILY______________ TWA STEL ppm mg/m-* ppa mg/m* PEL ppm mg/m-* REL Uranium Insoluble compounds, as U Soluble compounds, as U 1418 1419 7440-61-1 0.2 0.6 0.25 0.2 0.6 0.05 Vinyl cyclohexene dioxide - 142b Skin 106-87-6 10. A2 60. A2 None Wood Dust, hardwood 1430a 1 None SL 062037 4 i July 25. 1988 Tabulation of NIOSH Reviews of Proposed PLs NIOSH Table N6A - Proposed PELS That Meet the OSHA Definition of "Potential Occupational Carcinogen" (NIOSH concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER TLV TWA STEL ppm mg/m3 ppm mg/m3 PEL ppm mg/m3 REL Aldrin - Skin 309-00-2 0.25 0.25 Lowest re)iably detectable level Anisidine (o-. p-isomers) Sk in 29191-52-4 0.1 0.5 0.5 Chlordane - Skin 57-74-9 0.5 2 0.5 Oi eldrin - Skin 60-57-1 0.25 0.25 Lowest re)lable delectable level Dinitrotoluene - Skin 121-14-2 1.5 1.5 Reduce exposure to feasible level Heptachlor - Skin 76-44-8 0.5 0.5 Hexamethyl phosphoramide 680-31-9 A2 A2 None Propylene imine - Skin 75-55-8 2.A2 5, A2 25 1 ,1 ,2-Trichloroethane 79-00-5 10 45 10 45 Reduce exposure to lowest feasible level SL 062038 5 July 25. 1908 Tabulation of NIOSH Reviews of Proposed PELS NIOSH Tab e N6B - Proposed PELs That Heel the OSHA Definition of "Potential Occupational Carcinogen' (NIOSH non-concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER Acetaldehyde Asphalt (petroleum) fumes 1001 1028 75-07-0 8052-42-4 Beryllium & compounds, as Be 1033 7440-41-7 lit TWA STEL ppm mg/m-* ppm mg/m* 100 180 150 270 5 0.002.A2 PEL ppm mg/m3 200 360 None 2 Pg/m3 TWA. 5 Pg/m3 Ceiling. 25 Pg/m3 Ha* Ceil ing (30 min) REL 5 mg/m3 ceiling measured as total particulate (15 min) Not to exceed 0.5 Pg Be/m3 Chlorinated camphene - Skin 1018 Chromic Acid and chromates 1092 8001-35-2 7440-47-3 0.5 0.05 ' 0.5 C 0.1 25 Pg/m3 TWA 50 Pg/m3 ceiling (15 min) Chromyl chloride 1094 14977-61-8 0.025 0.15 I Carcinogenic Cr (VI): 1 Pg/m3 TWA; DDT (Dichiorodiphenyltrichloroethane) 1113 50-29-3 1 1 p-Dichlorobenzene 1125 106-46-7 75 450 110 675 75 450 Epichlorohydrin - Skin 1158 106-89-8 2 10 5 19 lowest reliably detectable level; 0.5 TWA Occupational exposure to epichlorohydrin to be Minimized SL 62039 l July 25, 1988 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N6B - Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen (NIOSH non-concurrence} CHEMICAL NAME HS NUMBER CAS NUMBER ___________ LLV______ TWA STEL ppm mg/3 ppm mg/m3 ppm PEL mg/m3 REL Ethyl acrylate - Skin 1161 140-88-5 5 20 25 100 25 (NIC 15 61) 100 Gasoline 1185 8006-61-9 300 900 500 1,500 None Hydra;ine - Skin 1205 302-01-2 0.1,A2 0.1.A2 1 1.3 0.03 ppm (0.04 mg/m3} ceiling (120 min) Methyl bromide - Skin Methyl chloride 1253 74-B3-9 1254 74-87-3 5 20 20 80 Exposure should be reduced to the lowest feasible level 50 105 100 205 100 ppm TWA, Exposure to methyl chloride, 200 ppm Ceiling. should be reduced to 300 ppm Max Ceiling, the lowest feasible level (5 min >in 3 hr) 4,4'Methylene 1273 bis(2-chloroaniline) - Skin Ni ckel Soluble or (inorganic) compounds, as Ni 1283 101-14-4 7440-02-0 0.02.A2 0.22.A2 0.1 PEL revoked by OSHA August 1975 3Pg/m3 TWA (lowest detectable 1imit) , 15 Pg Ni/m3 TWA p-Nitrochlorobenzene 1286 100-00-5 (NIC 0.5 0.1 3 0.6) 1 2-Nitropropane 1291 79-46-9 10.A2 35.A2 25 90 Reduce exposure to lowest feasible level SL 062040 2 NIOSH Tab e NnU Tabulation af N^OSlI Reviews o Proposed PELs Proposed PELS That Hi et the OSHA Oefini ion of "Potential 1.cupational Carci nnyen N10SH non-concurri ice) Jjly 25. 1988 *- CHEMICAL NAME HS NUMBER CAS NUMBER TLV__________________ TWA STEt ppm mg/er* ppm mg/er* ppm PEL mg/m^ PEL Perchloroethylene 1308 127-18-4 50 335 200 1.340 100 ppm TWA, Minimize workplace exposure 200 ppm Ceiling, levels; limit number of 300 ppm Max Ceiling. workers exposed (5 min in 3 hr) Phenyl glycidyl ether (P6E) 1315 122-60-1 1 6 10 60 1 ppm (5 mg/nr*) ceiling (15 min) Phenyl hydrazine - Skin 13W 100-63-0 5.A2 20. A2 10.A2 45.A2 5 22 0.14 ppm 10.6 mg/m^) ceiling (120 min) Propylene dichloride Propylene oxide 13d) 1344 78-87-5 75-56-9 75 350 110 510 75 350 20 50 100 240 Rosin core solder pyrolysis products, as formaldehyde 1350 0.1 None 0.) ppm ceiling (15 min) Silica -- Crystalline Quartz Tripoli Silica, fused 1355 1357 1350 14808-60-7 1317-95-9 60676-66-0 0.1. Respirable dust 0.1 , Respirable dust 0.1, Respirable dust 10^{XSi02*2), Respirable dust 10*(XSi02+2>, Respirable dust 10*(XSi02+2>. Respirable dust 50 Pg/m^ TWA. respirable free. silica p-Toluidine - Skin 1400 106-49-0 2.A2 9.A2 None 3 SL 062041 CHEMICAL NAME Vinyl bromide Vinylidene chloride Melding fumes Mood Dust, softwood 2inc chromate, as Cr July 25, 1988 Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N6B - Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen (HIOSH non-concurrence) HS NUMBER CAS NUMBER Hi TWA STEL ppm mg/m3 ppm mg/m? ppm PEL mg/a? REL 1425 593-60-2 5,A2 20. A2 None Controlled as specified for vinyl chloride in 29 CfR 1910.1017 with eventual goal of zero exposure 1428 75-35-4 5 20 20 80 None Controlled as specified for vii chloride in 29 CFR 1910.1017 w eventual goal of zero exposure 1430 5.B2 None Lowest feasible level 1430b 5 10 None 1436 13530-65-9 0.05.A2 (NIC 0.01,A1) 0.1 Carcinogenic Cr (VI): 1 Pg/m3 TWA; other Cr (VI): 25 Pg/m3 TMA; 50 Pg/m3 ceiling (15 min) SL 062042 4 T CHEMICAL NAME Arsine Benzo(a(pyrene tert-Butyl chromate, as Cr03 - Skin Carbon black Chlorodiphenyl - Skin (42% Chlorine) Chlorodiphenyl - Skin (54% Chlorine) Tabulation of NIOSN Reviews of Proposed PELs NIOSH Table N6B - Proposed PELS That Meet the OSHA Definition of "Potential Occupational Carcinogen" {NIOSH non-concurrence) July 25, 1968 a HS NUMBER CAS HUMBER 7784-42-1 Hit TWA STEL ppm mg/m-* ppm mg/m* 0.05 0.2 ppm 0.05 PEL mg/m* 0.2 REL 2 Pg As/m* (0.002 mg As/m*( ceiling (15 min) 50-32-8 1189-85-1 A2 C 0.1 None C 0.1 1 Pg/m* TWA 1333-86-4 53469-21-9 11097-69-1 3.5 '2 0.5 1 3.5 0.5 3.5 mg/m* 1 HA; 0.1 my/m* 1WA in presence of polycyclic aromatic hydrocarbons 1 Pg/m* TWA (the minimum reliably detectable concentrat ion using the recommended sampling and analytical methods) 1 Pg/m* TWA (the minimum reliably detectable concentrat ion using the recommended sampling and analytical methods) SL 062043 5 July 25, 1988 Tabulation of NIOSH Reviews of Proposed PELs NIGSH Table N6B - Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen (NIOSH non-concurrence) CHEMICAL NAME HS NUMBER CAS NUMBER 1LV. TWA STEL PP* mg/m3 ppm mg/m3 PEL ppm m$/m3 REL Chromite ore processing (Chromates) as Cr 0.05.AI l 25 Pg/m3 (0.025 mg/m3 IWA; 50 Pg/m3 (0.05 mg/m3 ceiling (15 min) as noncarcinogenic Cr (VI) Chromium (VI) compounds, Cr Water soluble Certain water insoluble 0.05 0.05.AI 0.5 Carcinogenic Cr (VI): 1 Pg/m3 TWA; Carcinogenic Cr (VI): 1 Pg/m3 TWA; other Cr (VI): 25 Pg/m3 TWA; 50 Pg/m3 ceiling (15 min) Chrysene 218-01-9 A2 A2 None To be controlled as an occupational careinogen Coal tar pitch volatiles, as benzene solubles Dimethyl carbamoyl chloride 65996-93-2 79-44-7 A2 0.2,A! A2 0.2 None 0.1 mg/m3 TWA (cyclohexaneextractable Tract ion) Reduce exposure to lowest feasible 1imi t 1, t-Oimethylhydrazine - Skin 57-14-7 0.5.A2 1.A2 0.5 0.06 ppm (0.!S mg/m3) ceiling (120 min) SL 062044 6 CHEMICAL NAME Ethyl chloride Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table N6B - Proposed PELs That Meet the OSHA Definition of "Potential Occupational Carcinogen'' (NI05.H non-concurrence) July 25. 10S8 e HS HUMBER CAS NUMBER 75-00-3 TLV TWA STEL PP" mg/m^ ppm mg/m3 1,000 2.600 ppm PEL mg/m3 1,000 2,600 REL To be handled in the workplace with caution because of structural similarity to carcinogenic chloroethanes Lead chromate as Cr Methyl hydrazine - Skin 7758-97-6 0.05.A2 60-34-4 C 0.2.A2 C 0.35.A2 None C 0.2 C 0.35 Carcinogenic Cr (VI): 1 Mg/m3 TWA; other Cr (VI): 25 Pg/m3 TWA; 50 Hg/m3 ceiling (15 min) 0.04 ppm (0.06 mg/m3) ceiling (120 min) Nickel sulfide roasting, fume & dust, as Ni N-Phenyl-beta-naphthyl amine Propane sultone o-Tolidine - Skin 135-86-6 1120-71-4 119-93-7 A2 A2 A2 i.Al A2 A2 A2 None None None None 15 Pg Ni/m3 TWA Reduce exposure to lowest feasible level 20 Mg/m3 ceiling (60 min) SL 062045 7 CHEMICAL NAME Butyl mercaptan Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table NT - Proposed PELs as TMAs for which NIOSH Recommends a Ceiling HS NUMBER CAS NUMBER TLV TWA STEL ppm mg/m3 ppm mg/m3 PEL ppm mg/m3 1054 109-79-5 0.5 1.5 10 35 Hydrogen sulfide 1209 7783-06-4 Isopropyl glycidyl ether (1GE) Hethyl chloroform 1227 1255 4016-14-2 71-55-6 Methyl mercaptan 1263 74-93-1 10 . 50 350 0.5 14 15 21 20 ppm Ceiling; 50 ppm Max Ceiling (10 min) 240 75 360 50 240 1,900 450 2,450 350 1.900 1 C 10 C 20 Petroleum distillates 1312 (Naphtha; Rubber solvent) 400 1,600 None July 25. 1988 p * REL 1-Butanethiol: 0.5 ppm (1.8 my/m3) ceiling (15 min); mixtures of thiols to be controlled by calculation of equivalent concentrations 10 ppm (15 mg/m3) ceiling (10 min) 50 ppm (240 mg/m3) ceiling (15 min) 350 ppm (1,910 mg/m3) ceiling (15 min) 1-Methanethiol: 0.5 ppm (1.0 mg/m3) ceiling (15 min); mixtures of thiols to be controlled by calculation of equivalent concentrations 350 mg/m3 TWA; 1,800 mg/m3 ceiling (15 min); blood and urine monitoring required; action level: 200 mg/m3 TWA SL 062046 l CHEMICAL NAME Phenyl mercaptan Vanadium, as V205 Respirable dust Fume July 25. 1988 HS NUMBER Tabulation of NOSH Reviews o' Proposed PELs MO I Table N7 - Proposed `its as IWAs For wl ich NTOSH Recomme ti > a Ceiling CAS NiJHBER ____________ li________________ TWA SIEL PEL ppm mg/m^ ppm mg/m^ ppm mg/m^ REL 1316 108-98-5 0.5 2 None Benzenethiol : 0.1 ppm (0.5 mg/m^) ceiling (15 min) mixtures of thiols to be controlled by calculation of equivalent concentrations 1421 1422 1314-62-1 0.05 0.05 0.5 (dust) 0.1 (fume) 0.05 mg/m^ ceiling (15 min) 0.05 mg/m-* ceiling (15 min) O620^7 2 CHEMICAL NAME Benzyl chloride Cyanides, as CN - Skin Sodium cyanide Potassium cyanide Hydroquinone Phenol - Skin Phosgene Tabulation of NIOSH Reviews of Proposed PELs NIOSH Table NT - Proposed PELs as TWAs for which NIOSH Recomends a Ceiling HS NUMBER CAS NUMBER ILK TUA STEL ------------------------------------- ppm mg/m3 ----------------------------- ppm mg/m3 PEL ------------------------------ppm mg/a3 100-44-7 IS 15 REL --------------------------------------------------------------- 5 mg/m3 ceiling (IS min) 151-50-6 143-33-9 123-31-9 108-95-2 5 5 2 19 J5_4d_5 0.1 0.4 S 2 5 19 0.1 0.4 4.7 ppm (S mg CN/m3) ceiling (10 min) 0.44 ppm (2 mg/m3) ceiling (15 min) 5.2 ppm (20 mg/m3) IWA; 15.b ppm (60 mg/m3) ceiling (IS min) 0.1 ppm (0.4 mg/m3) TWA; 0.2 ppm (0.8 mg/m3) ceiling (IS min) SI. 062048 3 a -* Tabulation of NIOSH Reviews of Proposed PELS Kev to Abbreviation c Ceiling CAS Chemical Abstracts Service Chemica1 Name HS The chemical name listed may be a mixture of common, IUPAC and/or trade names as used by OSHA Number designated by OSHA for this health standard rulemaking Micrograms per cubic meter g/m3 NIC Mi 11igrams per cubic meter Notice of Intended Change by ACGIH as listed in 1987-1988 TLVs NOC Not otherwise classified PEL Permissible Exposure Limit (OSHA) ppm Parts per million REL Recommended Exposure Limit (NIOSH) STEL Short-Term Exposure Limit (ACGIH) TLV Threshold Limit Value (ACGIH) TWA Time-Weighted Average SL O62049