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f L IA14607 Lead Industries Association, Inc. m Medteoe MM Nn Yert. N. Y. 10017 Teef*one: (317) M3 7J7J o Environmental Heelth Department February 4, tt71 To: All Member* of th Load Industrie* Association, IDC. From: J. F. Cola, Director, Environmental Health 71 *'------D. A. Lynam, As list ant Director, Environmental Health y Subject: The Occupational Safety and Health Administration Tantet Health Hazard Protran Centlemen: The Department of Labor held meetings on January 26 and February 2 to discuss the Occupational Safety and Health Administration Target Health Hazard Program (TXHP). Lead, asbestos, silica, cotton dust and carbon moooxld* are the materials chosen as target health hazards by the Department of Labor. The criteria used In selecting the flee listed materials from among all the poaslble employee exposures were the following: 1. Large numbers of employees exposed; 2. High national Institute of Occupational Safety and Health QH0S1) priority; 3. Existing applicable standards; 4. Compliance feasibility. Mr. Ceorge Cuenther, Department of Labor, Aaalatent Secretary, Occupational Safety and Health, addressed himself to a description of the hazards presented by each of the materials. The context of the lead description Is Included In the attached target health hazard fact sheet. Mr. Cuenther further emphasized that the five target health hatards will be the subjects for an accelerated Inspection and compliance program by OSHA. Emphasis will be placed on Industrial hygiene services In the Industries where exposure to these materials Is suspected. Dr. Edward Fairchild, Aasoclate Director of HIOSH at the January 26 meeting and Dr. Marcus Key, Director of MIOSH at the February 2 meeting, noted that separate evaluation of health hazards had produced a Hat quite similar to that of OSRA. HIOSH used various Indices Including relative toxicity Incidence and so on, and tha asms five substances appeared In the top of their Hat with the exception of aabeatoa. Asbestos was added because of the recent concern about this material. Dr. Fairchild noted that criteria documents are now being prepared on a contract basis for MIOSH. Tha asbestos document Is now completed and criteria documents for several other substances Including lead and cadmium ara among those now being developed. Mr. Fred Blschoff, Director of Compliance for OSHA, described the compliance approach for the target health hazard program. In substance. It does not differ from the Inspection procedure which OSHA has baan using up to this point with the exception that emphasis will be placed on the five target health hazards. ; Detailed description of the aaapllng procedure and aqulpment which OSHA will use In Its compliance program It as follows. Tha sample la collected by usa of a Mina Safety Appliance Company Parsonnel Saaplar operated at a flow rata of 1.2 liters/minute mmm -IliHllllTV ii'sHiMs L N 3471.01 & ' i `i on to 37 an diameter filter*, filter type AA (0,40 micron mein pore dleneter). Although not brought out In the formal prceentitlon, It wee noted during the Informal eeielon that the filter le open-faced, but It covered by a pleetlc cover, and con tain* a plug. The plug 1* removed during the templing period. Therefore, although the filter holder 1* referred to a* open-faced. It doe* actually have a cover. The (tuple 1* analysed by atonic absorption vith a lover Halt of detection of 0.003 ag of lcad/fllter. Up to five puap* will be used by the Compliance Office and the eaapllng tlae will vary froa 60 aloute* to 8 hour* and che possibility exl*t that periodic *aaplet of 6 to 8 alnutea per hour throughout the work period can be taken. Attention 1* called to the fact iheet regarding approved level* of lead. American Rational Standard* Inatltut* Standard 237.11-1969--Acceptable Concentration* of Lead aod the Inorganic Compound*, 1* the applicable ctandard and the exposure limit la 0.20 ag/a^. Levela above 0.6 agfmr are considered a terloua violation while level* j of 0.2 to 0.6 are contldered regular or noo-**rlou* violation*. Titneat danger 4 ltuatlona are not generally applicable. i In reeponaa to a question by Dr. Cole, Mr. Guenther noted that biological monitoring la being given consideration by KI0SH and It 1* likely that biological limit value* will be established. However, until such limit* are established, OSBA feel* that It can do no other than to rigidly enforce the air quality strndard*. i It 1* certain that an advisory comltte* will be established under 0SHA to advise on changes In the standard for lead. Mr. Cuencher noted that many representative* on this committee are likely to be chosen froa those present at the sessions. It was noted that OSHA welcoaed the "input of Industry Into standards setting,** and Dr. Fairchild, In response to a question, noted that KIOSH welcoaed any data )Ailch Industry may have for Inclusion Into criteria packages. Further, on criteria packages. Dr. Fairchild stated that prior to submission of their recoenendacions to 0SRA for standards, these criteria packages would be subject to both Internal (KIOSH) and external (Industry) review. Hr. Cuanther suggested that the Department of Labor prefer* to work with Industry trade associations because of tbclr broad base of support and because they ere directly representative of the various positions of their members. An additional question concerned the Department of Labor's position on the us* of respirators oo a part -1 la* or perhaps even a full-tlae basis so as to reduce the tine-waited-average exposure to less then the Threshold Limit Value. It appeared that the possibility exists that no citation would be Issued In an area diere th* exposure exceeded the Threshold Ltalt Value if respirators were being used by all employees In the area. However, th* employer would be required to abate the condition by engineering aeana. Th* TKHP has a very high priority in th* Department of Labor list of inspection schedules. The greatest priority Includes Inspections of exposures Involving fatalities and Inspection* originating due to coa^lalnts Is next In line of priorities. The TKHF follow* In priority. In view of this high priority for th* TKHF, It Is believed that all of th* facllltle* which have exposure* due to lead can expect to be Inspected, If additional Informstion or assistance is oeeded, pleas* do not hesitate to contact us. cbt Cnc. Lei rrij^'tiHf'itfiftSBlsa^- -, Target Health Hazard Fact 8heet LEAD WHAT IS ITT Lead li a oft, dense, malleable, baavy artal with a low Baiting point. It la grsy In color and, because of lta cbaractariatlca, baa a vide application of usea. WHERE IS ITT Lead la uaad to Babe printing type and pluriblng, shield telephone and pover cables and to protect against radiation hazards. As an all^r, lead nixed vith steel Bakes excellent bearings. As solder, lead alloy la vital In the electrical and electronic Industries, lead compounds are used to Bake paints and aaaunltioa, and lead oxides are used In car batteries. i WHAT IS THE HAZARD? Hore than 1.6 nlllioc employee* la nearly every Industrial manufacturing process and In many service Industries are exposed to the poisoning effect of lead. Lead can enter the body by inhalation, absorption through the skin or by ingestion. In sufficient quantities, the result Is the saae -- severe gastrointestinal, blood and central nervous systea disorders. Inhalation of lead dust or 1 fxes Is the aost frequent Beans of entry and results In most of the Industrial health probleaa Involving this Betel. Lead la a emulative poison. A part of a ssall dally doae is not eliminated, but is stored In the body. Eventually, a point Is reacbed where symptoms and disability -- even death -- occur. HCV IS IT CORTROLLEDl Since the primary route of Industrial lead poisoning It Inhalation, enclosura and local sxhaust ventilation are the principal Beans of control. Dally vet or vacuum cleaning of all lead dust, personal hygiene, prohibition of food and beverages In the work area and use of U.S. Bureau of Mioe-approved respirators are other Beans that can help control exposure. WHAT AKE APPROVED LEVELS! OSHA's permissible level Is 0.2 Bllllgraas per cubic meter of sir for an eight-hour, tlce-velghted, average airborne concentration. Imminent danger situations are not generally applicable- Any exposure above 0.6 Bllllgraas per cubic meter of air for an eight-hour, time-weighted average is considered a serious violation. Levels above 0.2 and leas than 0.6 are considered regular or nonserlous violations. HCW IS IT MEASURED! The atmosphere Is stapled with personal sampling pumps and filters for a mlnimvai of 60 minutes. '* i 1 N 3471.02