Document BR5Q1eYbDVoOG9MRrBMqyzQKj

INTER-OFFICE CORRESPONDENCE Date: February 27, 1991 To: Tom Brown From: Roger Corley Location: General Office Subject: Compliance Deadlines I have looked into compliance deadlines for OSHA 1919.1000 at your request. I looked specifically at ethylene dichloride as the substance of particular interest at this time. The key finding is that the deadline for compliance through engineering controls is December 30, 1993. This is an year more than may have been believed by some. I have attached a few pertinent pages of the 1910.1000 standard and marked the key paragraphs for easier reading. To walk through the logic: 1. Item #1 allows achievement of the Permissible Exposure Limits by any reasonable method, including respirators, until December 30, 1992. At that time, Item #1. prevails. 2. Item #2 dictates that engineering and administrative controls be used to achieve compliance, with other means used only if engineering and administrative controls are not feasible. 3. However, if OSHA fails to publish a final standard on Methods of Compliance by December 31, 1991, then two important exceptions come into play. This paragraph is item #3. 4. These two exceptions are found in item #4. a. The compliance deadline for engineering controls is extended one year to December 30, 1993, as noted above. b. The exposure limits during this period are those listed as "Transitional Limits" in Table Z-2. These limits are higher, specifically 50 ppm TWA instead of 1 ppm as shown in the "Final rule limits". After December 30, 1993, the limits will revert to 1 ppm TWA. There will be no relief from the requirement to achieve this exposure limit through engineering and/or administrative controls at that time, unless there is some amendment or change in the regulations. cc: David Angell Ed Kennah Bob McCorquodale Bob Rubino ACCIDENT FREE DAYS ARE ACHIEVED ONE AT A TIME THE ACCIDENT PREVENTION PROCESS IS THE KEY SL 091904