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standards. The action level concept would result in wasteful utilization of manpower with no additional health protection to the employee, the company said. According to the com pany, "many years oC experience" with two of the ketones would indicate that an action level beneath the threshold limit value would be "unnecessary for the protection of the
employees' health." Exxon objected also to proposed requirements for the use
of feasible engineering and work practices to reduce ex posure. even if these measures are not sufficient to reduce exposure to the permissible level. The company recommend ed instead that employers be required to insure proper selec tion of respirators, instruct employees in their proper use, and supervise their use by employees.
Deletion of the action level concept was recommended also by William C. Janes, manager, environmental health, United States Steel Corporation, Pittsburgh, Pa. In addition, the company recommended that frequent periodic sampling not be required for ketones, because the toxic effects of these substances are due to massive, acute exposure rather than to chronic exposure.
Clayton D Ruyle, executive secretary, industrial relations committee. Aerospace Industries Association of America, Inc., Washington, D.C., said no evidence has been presented to show that ketones are so hazardous as to warrant "the stringency and cost of the proposed standards."
According to the association, the action level concept, together with "the hierarchy of compliance methods" in cluded in the proposed regulations, is an attempt to set an
unjustified" design standard. Donald L. Morgan, counsel, OSHA Standards Task Force of the Synthetic Organic Chemical Manufacturers Associa tion. Washington, DC., said the task force "does not perceive a need for complex standards for such relatively non-toxic substances as these ketones." SOCMA objected to "the apparently uniform approach" to the standards com pletion project, because different substances may present different types of risks to employees, and to the derivation of language in the proposed ketone standards from standards for carcinogenic and highly toxic substances. SOCMA recommended that the action levels for the ketones be the same as the threshold limit values for the sub stances In addition, regarding proposed requirements for medical surveillance, the association said that rules which would require employers to provide medical examinations for employees who complain of symptoms of ketone ex posure could "lead to mass hypochondria" and "foster problems in labor relations, absentee control, and overloading of medical services and facilities." Bruce Hamill, counsel, National Paint and Coatings Association, Washington, D.C., said the action level for each ketone should be the sdme as the permissible exposure level, as "the documentation for the levels at which OSHA current ly regulates the materials clearly demonstrates the nonhazardous nature of the materials when used at that level." Additionally, NPCA called proposed methods for exposure determination and measurement "erroneous and inexact," adding that a safe workplace can be assured only by the use of trained individuals employing a properly designed and ex ecuted survey. The association said also that proposed rules for medical surveillance "will impose oppressive un warranted burdens," and that the entire concept of in dustrial medicine should be investigated thoroughly by OSHA before such requirements are issued. Edwin M. Hood, president, Shipbuilders Council of America, Washington, D.C., said the establishment of an ac tion level at a level below the threshold limit value "is not in
321
keeping with the intent ortlre TLV concept." The TUV. the council said, should be the level for establishing controls.
The council said continuous bimonthly monitoring was not necessary for contamination levels above the action level and below the permissible exposure level. According to the council, two or three consecutive bimonthly samples with the same results should be sufficient evidence of actual con centrations.
The proposed regulations for ketones appeared in the May 8 Federal Register (Current Report, May 15, p. 1654).
Legislation
HOUSE PASSES AMENDED LEGISLATION PERTAINING TO POSTAL WORKER SAFETY
The House passed an amended bill which would place the safety and health of employees of the U S. Postal Service un der the jurisdiction of the Occupational Safety and Health Act.
The bill, HR 2559, previously was passed by the Senate with an amendment which would raise the pay of federal judges and congressmen. It was sponsored by Congressman Charles E. Wilson (D-Calif).
The bill makes applicable to the Postal Service, Section 19 of OSHA which provides that each federal agency head be responsible for developing and carrying out an effective safety and health program for his employees (Current Report, June 26, p. 134). It is awaiting White House approval.
Variances
VINYL CHLORIDE INTERIM ORDERS DRAW NO RESPONSE FROM UNIONS. OSHA SAYS
No official response has been received by the Occupational Safety and Health Administration from unions or employees on the issuance of interim orders to three companies pending decisions on the firms' applications for variances from re quirement of the vinyl chloride standard, an OSHA spokesman told OSHR.
Firestone Plastics Company (Current Report, June 5, p. 22) , Keysor-Century Corporation (Current Report, June 5, p. 23) , and Stauffer Chemical Company were the companies granted the interim orders.
Stauffer received separate interim orders for installations in Westport, Conn'. (Current Report, April 24, p. 1554), Carson, Calif. (Current Report, May 8, p. 1636), and Dobbs Ferry, N.Y. (Current Report, June 19, p. 100).
According to the OSHA spokesman, the only union involve ment in the applications for variances occurred when Firestone issued its request for a variance. In a telegram dated April 9, 1975, Peter Bommarito, president, United Rubber Workers International Union, Akron, Ohio, told OSHA that "we do not feel that Firestone has acted in good faith" in seeking a variance.
Regarding Firestone's contention that it was unable to comply by the effective date with respitator requirements in Section 1910.1017 (g) (4), the union said, "it appears that Firestone had already been given enough time to make respirators available to all employees exposed to vinyl chloride, especially employees exposed to levels above 25 ppm."
The telegram continued, "The United Rubber Workers employees respectfully contest the Firestone request for
Copyright 1975 by The Bureau of National Adairs, Inc.
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OCCUPATIONAL SAFETY & HEALTH REPORTER
t ii-mporary variance from the vinyl chloride standard,'1 and
NIOSH
added, "further documentation will be forthcoming " However, according to the OSHA spokesman, no further
documentation" was sent by the union. The spokesman add ed that a meeting was held in Washington, D C., last spring between URW representatives and representatives from the OSHA Office of Standards Development and the Office of Compliance Programming, and that communications are
While noise-induced stress may be a factor in disease, the issue ol whether excessive sound exposures can directly or indirectly lead to permanent health disorders remains con troversial, John F. Finklea, director, National Institute for Occupational Safety and Health, told the subcommittee.
Loud noise can result in changes of the cardiovascular,
endocrine, neurologic, and other physiologic functions to
continuing between OSHA. Firestone, and the union. The spokesman added that Firestone was found recently to
be in compliance with the respirator standard for levels both beneath and above 25 ppm.
create a generalized stress reaction of the body, Finklea said. He added that the inability of past research on stress effects to eliminate other factors which could lead to the health problems supposedly caused by high level noise ex
posures raises questions about the conclusions
A recently completed NIOSH study linked noise exposure
Noise
to medical, attendance, and job accident problems. The con tract research, which studied the medical, attendance, and
SUBCOMMITTEE HEARS DATA ON NUMBER OF OSHA CITATIONS FOR NOISE IN THREE YEARS
accident record of 400 workers in a boiler making plant for two years prior to the establishment of a hearing conserva tion program and two years after, showed significant reduc
There were 10,641 noise samples taken by the Oc cupational Safety and Health Administration from January
tions of worker problems in the three areas. Comparable records from a control group showed no substantial change
1973 to March 1975 resulting in 9,018 citations for noise dur
during the same two time periods. The research suggests
ing the period, Alexander J. Reis, OSHA associate assistant
that a hearing conservation program can be helpful in reduc
secretary for national programs, said on July 25. Testifying on industrial noise before the Senate Select
Committee on Small Business, Reis submitted data on the noise-related violations observed during the last two and one-half years by size of establishment and type of industry
ing extra-auditory problems of noise exposure as well as hearing loss, Finklea said.
Outlining NIOSH's efforts to improve technology of noise abatement, Finklea noted that the agency has prepared lists of performance data for various ear plugs and muffs and has
inspected. The data suggest noise citations were issued most often in
published procedures for rating the effectiveness of the devices. In addition, NIOSH presently is working on methods
establishments with from 100 to 249 employees, and most violations occurred in manufacturing industries. Reis said the Environmental Protection Agency's coordinating func tion is important because of the number and variety of federal programs that can affect the noise problem.
Thomas Kleppe, administrator, Small Business Ad
for measuring the performance of ear plugs in use and the agency is attempting to "refine" noise survey methods and techniques for audiometric testing.
Finklea also said two noise control handbooks are being developed by NIOSH to provide small employers with a catalog of noise reduction materials and suppliers and to
ministration, said many small firms will have to pay to meet either an 85 or 90 dBA noise level in the workplace. It would be much better from the standpoint of small business to offer
present case histories of engineering solutions as a guide for noise control.
the option of providing employees with ear plugs or other
protective devices, rather than the alternative of having to
replace machinery or facilities to meet the new noise level standards. "Even better would be an exemption for the
Noise
smallest of the smalls," Kleppe said. He described the SBA loan program, available for aid in
compliance with OSHA, and said that, to date, SBA has made 38 loans for a total $10,9 million. Kleppe said SBA and OSHA signed a new memorandum of understanding delineating responsibilities in providing financial assistance to small business.
RELIANCE ON PROTECTIVE EQUIPMENT SHOULD BE CHOICE OF OSHA. INDUSTRY SAYS
The Occupational Safety and Health Administration's re jection of personal protective equipment as a primary means of controlling worker exposure to excessive noise is unfair, unreasonable, and inflationary, according to testimony presented by various industry representatives at
Newspaper Guild
hearings on the proposed occupational noise rule.
Robert M. Crocker, international secretary-treasurer, The
The hearings, which began June 23, concluded July 30
Newspaper Guild, AFL-CIO, said a serious noise problem
after oral testimony from some 138 labor, medical, industry,
that is not well-known exists in wire rooms of newspapers
and government representatives. The Labor Department
and in bureaus of the wire services where decibel levels in
gave no indication as to when it would issue a final noise
the 80 s and 90 s and above have been recorded.
standard. (See related articles this issue).
Crocker said the Wire Service Guild recommends con
The B.F. Goodrich Company told OSHA that the proposed
sideration be given to basing permissible noise levels on the
standard places "unwarranted burdens" on the employer
World Health Organization study that recommended 60
even though it provides more adequate protection for
decibels as the maximum in any environment in which
noise-sensitive employees than the presently enforced rule.
employees must work for prolonged periods. WHO
Roger Strassburg, Goodrich director of environmental af
recommended also that employees working on a daily or
fairs, urged OSHA to take a compromise position with the
hourly basis in areas having a noise level of 70 decibels be
final workplace noise rule and allow a balanced program of
given employer-paid hearing tests annually; and that an
feasible engineering controls and effective hearing protec
employer demonstrating the ability to upgrade health and
tion.
safety standards in any of its facilities be required to apply
Strassburg told OSHA that a hearing conservation
its highest standards throughout all facilities, he said.
program for the 60 to 70 percent of B.F. Goodrich's
Occupational Safety & Health Reporter
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