Document Z438gnoerZxOa4YGEy3VLaeDV
OSHA Proposes New Health Standards
Asbestos: In light of new scientific evidence, exposure limit cut to 0.5 fibers per cubic centimeter.
Toluene: Exposure limit halved, and new requirements for medical exams, recordkeeping, monitoring, and training added.
Standards Completion Project: Exposure limits unchanged, but complete standards written for alkyl benzenes, ketones, cyclohexane, and ozone.
ASBESTOS
Reductions in permissible exposures and ceiling limits are among proposed changes to osha's job health standard on asbestos (1910.1001). The proposed revision was published in the Federal Register October 9.
The preamble to the proposal stresses that it is osha's intention to safeguard employees wherever asbestos or a product containing as bestos is manufactured, processed, packaged, stored, applied, used, or otherwise handled, but that it is not osha's intention to create any un due administrative or economic burdens on em ployers, particularly those who have only a few workers or a highly transient workforce. Written comments or requests for a public hearing were invited, as well as comments on environmental and inflationary impact.
Asbestos in its various forms is said to have more than 1,000 uses; the fibrous mineral has been known for 2,000 years and widely used industrially for 100 years.
The United States uses more than 800,000 tons of asbestos annually: 27 percent in as bestos cement pipe and sheet; 19 percent in vinyl asbestos floor tile; 12 percent in sheet vinylflooring; 10 percent in roofing papers; and smaller percentages in gaskets and packing, friction materials, pipe and thermal insulation, coatings and compounds, plastics, and miscel laneous uses.
An estimated 50,000 workers help make products containing asbestos, while apparently millions of others are exposed in secondary manufacturing involving use of such products. Occupational exposure may occur in industries including: asbestos fiber processing; manufac ture of asbestos-containing products; construc tion; shipbuilding; auto manufacture; and auto repair.
The current standard, issued June 7, 1972, limits worker exposure to an eight-hour timeweighted average (twa) of five asbestos fibers
per cubic centimeter of air (five million fibers per cubic meter of air); the ceiling limit is 10 fibers. Effective July 1, 1976, the 1972 rule would reduce the exposure limit to an eight-hour twa of two fibers.
Reexamination of the 1972 standard was based on new research developments regarding the harmful effects of asbestos exposure, plus advances in monitoring and protective technol ogy, over the last few years. Recent clinical data, for example, associate asbestos with producing not only asbestosis (non-malignant scarring of the lungs which, in its severe forms, can cause death); but also with cancers of the lungs, chest cavity, abdomen, stomach, colon, and rectum.
The diseases are progressive. Even in the ab sence of further exposure, inhaled fibers con tinue their biological action. Asbestosis and as bestos-caused cancer usually do not become clinically evident until 20, 30, 40, or more years after the onset of exposure, even when exposure has been short-term or intermittent.
Family contacts of former asbestos factory workers arc also showing an incidence of x-ray changes characteristic of asbestos exposure.
Calculations suggest that cigarette-smoking asbestos workers have approximately eight times the risk of developing lung cancer as other smokers.
Much of this clinical data on carcinogenicity was either not developed or not known to osha when the original standard was issued. Because the new evidence is that asbestos acts as a lung carcinogen at levels below those that will pro
duce asbestosis, osha's concern is reoriented toward the prevention of asbestos-caused cancer. Reduction of asbestos exposure enough to pre vent asbestos-caused cancer is also expected to prt vent asbestosis.
The October 9, 1975, proposed revision of the standard would:
Leave the construction industry under the initial standard and plan separate rulemaking to revise the asbestos standard for construction. (Approximately three-fourths of all asbestos products in 1972 were used in the construction industry.)
Modify definitions as follows: "Asbestos" includes chrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite, and every product containing any of these minerals; and "asbestos fiber" means a particulate form of asbestos, longer than five micrometers, with a length-todiameter ratio of at least three-to-one and with a maximum diameter of five micrometers.
Reduce permissible exposures to an eighthour twa of 0.5 fibers per cubic centimeter (500,000 fibers per cubic meter of air).
Reduce the ceiling limit, which would be determined during any 15-minute sampling pe riod, to five fibers per cubic centimeter.
Establish requirements for engineering con trols, work practices, and supplemental use of respirators and protective clothing.
Revise procedures for monitoring.
Suggest work practices to be followed for certain operations and processes involving as bestos.
Revise and update the requirements for respirators, referencing niosh as the approving authority. The proposal would not render any existing respirators obsolete, but would enable a greater variety of respirators to be used under different conditions of exposure.
Establish additional requirements for: reg ulated areas; hygiene facilities and practices (including a requirement for change rooms and showers); worker training and information pro grams; and warning signs and labels.
Require specific medical surveillance and minimum data on medical and monitoring rec ords.
Provide for job reassignment in case of medical unsuitability.
Extend the period during which the em ployer must retain monitoring and medical rec ords to 40 years, or employment plus 20 years, whichever is longer.
Provide procedures for the transfer of em ployees' medical and monitoring records when one employer succeeds another, or when an em ployer goes out of business.
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Appendices to be published with the stan dards will offer further information and guid ance.
TOLUENE
osha has proposed a new standard on tolu ene, an industrial chemical made primarily from petroleum. Under the proposal, which ap peared in the Federal Register October 6, the osha exposure limit would be cut from the pres ent 200 parts per million (ppm) of air to 100 ppm as a time-weighted average (twa) over eight hours. The proposal also sets up require ments for medical exams, recordkeeping, moni toring workplace air, and training employees.
Toluene (also known as methylbenzene, methacide, phenylmethane, toluol) is a clear, flammable liquid that evaporates at a moderate rate. About 70 percent of the more than one billion gallons of toluene manufactured in the United States each year is used to make ben zene; the rest goes into the production of other chemicals, solvents, and gasoline. The National Institute for Occupational Safety and Health (niosh) estimates that 100,000 or more work ers in the petrochemical, rubber, paint, glue, shipbuilding, construction, and automotive in dustries may be exposed to toluene on the job.
The prime health hazard arises when workers breathe high concentrations of toluene vapor. This depresses the central nervous system and often creates effect's similar to being drunk. Workers may get headaches, feel weak and drowsy, lose coordination, and display poor judgment. Extremely high exposures have caused test animals to lapse into coma and die if the exposure continues long enough.
The chief long-term effects are much like those of chronic intoxication--nervousness, in somnia. fatigue, loss of appetite. A few people exposed to very high toluene levels--glue-sniff ers. for instance--have suffered permanent brain damage. Though some workers have developed enlarged livers after repeated exposures, there is no evidence of permanent liver damage.
Early studies on toluene, which showed seri ous effects on the blood and blood-forming or gans. are now thought inaccurate because the toluene used was contaminated by benzene. In industry today the poorer grades of toluene may contain up to 25 percent benzene--a substance long known for its highly toxic action on the blood-forming organs.
osiia's current standard on toluene (the 200 ppm twa and a 300 ppm ceiling limit) is based on a 1943 American National Standards Insti tute (ansi) standard. Closely following recom mendations in niosh's criteria document on tol
uene and a 1974 revision of the ansi standard, osha proposes to lower the permitted twa to 100 ppm because studies have shown that work ers exposed for eight hours to 200 ppm experi ence mild fatigue, muscular weakness, and poor coordination. The proposal also would reduce the ceiling limit to 200 ppm as measured over 15 minutes.
Since toluene is a defatting agent, contact with the liquid can cause skin irritation and dermatitis after prolonged exposure. Splashed in the eyes, toluene will bring severe pain and burn the cornea if not flushed quickly with water. As a result, the proposal would require the em ployer to prevent any eye contact or repeated skin contact with liquid toluene among his em ployees.
Other key provisions include: Action level. In any workplace where tolu ene is used the employer must make an initial written determination of employee exposures. If any employees arc exposed above the "action level"--half (he permitted limit or 50 ppm--/ then monitoring and medical requirements go into effect. Monitoring. The employer may take cither personal, breathing zone, or general air samples as long as the method gives an accurate indica tion of each employee's exposure. If exposures are above the twa, monitoring must continue monthly. If employees are exposed above the action level (but below the twa), monitoring must be done once every three months. Em ployees must have the chance to observe moni toring and have the procedure and results ex plained to them. Training. The employer must tell employees about the hazards of toluene, explain the con trol procedures in effect, and instruct them to report any symptoms of overexposure. Medical surveillance. The employer must provide annual medical exams--including lung function tests, urinalysis and blood count--to all employees exposed above the action level. From the examining physician he must obtain a written opinion on whether individual workers would be harmed by further exposure to tolu ene. If they would, it is the employer's respon sibility to sec that affected employees are re moved from jobs involving hazardous exposures. Recordkeeping. The employer must keep records of medical exams and air sampling re
sults for at least 10 years and make these avail able to employees or their representatives.
Compliance. First, the employer must use engineering controls to bring toluene exposures within the iwa. If engineering controls and work practices can't accomplish this, the em ployer must use them to the extent feasible and
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supplement them with respirators to protect workers.
As we go to press, osha is conducting a study to determine whether an inflationary impact statement for the toluene proposal is necessary.
If an inflationary impact statement is required, it will be available to the public for review and
comment at least 30 days before the hearing on
the proposal. Comments on the proposed toluene standard
should be submitted to: U.S. Department of
Labor, osha. Docket Officer, Docket No. H-026,
Room N3620, Third and Constitution, NW,
Washington. D.C. 20210.
STANDARDS COMPLETION PROJECT
Job health standards proposed by osha on Oc tober 8 spell out compliance requirements for fast, comprehensive action by employers wher ever employee exposure to any of 11 toxic sub stances climbs above the halfway mark toward current exposure limits. The substances are: six alkyl benzenes (p-tert-butyltolucne, cumene, ethyl benzene, alpha-methyl styrene, styrene, and vinyl toluene); cyclohexane; three ketones (camphor, mesityl oxide, and 5-methyl-3-heplanone); and ozone.
Following publication of the proposed stan dards in the Federal Register October 8, osha invited the submission of public views and re quests for public hearings on the proposed standards or any issue raised in the standards. Comments on environmental or inflationary im pact also were invited.
In discussing the proposals, osha made dear that all issues raised are open to comment and subject to revision if the public record demon strates need and support for alternatives.
These 11 proposals comprise the second and third sets of rules drafted as part of the Joint osha-niosh Standards Completion Project (scp) begun in March 1974. Together with the first section on ketones, osha now has proposed 17 new rules under the scp. (See Job Safety and Health, June 1975, "The First of 400.")
The object is to flesh out existing regulations on workplace exposure to nearly 400 toxic sub stances by issuing new and more complete stan dards to guide the employer. These substances presently arc listed under Section 1910.1000 (formerly 1910.93) of osha's general industry standards, where permissible exposure limits for airborne concentrations arc expressed in terms of eight-hour workshift time-weighted averages (twa's).
osha's October 1 proposal would establish requirements for measuring exposure; engineer
ing and work practice controls; handling and use of liquid, solid, gas, or vapor forms of the substances; personal protective equipment; em ployee training; medical surveillance; sanitation; and recordkeeping.
The "action level" that would trigger these comprehensive safety measures is a determina tion that airborne concentration has reached 50 percent of the threshold limit values (tlv's) currently prescribed. In this way, the employer can adequately safeguard the health of the worker by acting on a problem as soon as he learns it is serious and before it becomes critical.
The newly written standards also would help the employer by providing cross references to other requirements in Part 1910 pertaining to the toxic substances addressed. An example of a referenced standard is Section 1910.106, which prescribes storage requirements for com bustible and flammable liquids in terms of flash points and boiling points. The proposed stan dard would inform employers of the proper classification of these-substances, how to deal with them, and how to comply with related regulations.
Billions of pounds of the toxic substances named in (he proposal arc produced annuallv in the United States. The chemicals are used primarily in the manufacture of synthetic rub ber, nylon, plastics, and resins; as chemical and pharmaceutical intermediates; and as solvents. They can be inhaled, ingested, or absorbed. Because use is widespread and diverse, the pre cise number of employees exposed is not know n.
Among the industries where exposure to these 11 substances may be most common are: rubber, pharmaceuticals, cosmetics, chemical manufacturing, shoemnking, plastics, food, to bacco. paint and coatings manufacturing, aero space. auto, shipbuilding, and steel.
Short-term effects of overexposure include ir ritation of the eves, nose, and upper respiratory tract: dizziness: nausea; and vomiting. In liquid form, mesityl oxide can produce corneal injury. Several of the toxic substances in (be group of 1 I are defatting agents, capable of causing the skin to crack and become inflamed. Sustained high levels of exposure to many of these 11 substances may lead to depression of the central nervous system, bone marrow injury, kidnev damage, inflammation of the lungs, dizziness, and unconsciousness. Damage to chromosomal structures may result from excessive exposure to ozone; the corrosive nature of ozone cas is believed to have biological elTcets similar to radiation.
osha proposes to require employers to: learn the possible hazards of chemicals used in their plants; determine whether conccnlralions have
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reached the "action level" and if so take neces sary steps to control the exposure; and make information about exposure available to em ployees.
Following are other major provisions of the osha proposals:
Permissible exposure limits are unchanged 'Trom those listed in Tables Z-l and Z-2 of Sec tion 1910.1000 of osha's general industry stan dards; these are not at issue in the current pro posal.
"Action level" is half the eight-hour timeweighted average exposure. If this level of exposure is reached, then the employer must begin specified procedures such as employee exposure measurement, training of employees, and medical surveillance.
Wherever any of the regulated substances may be released into the workplace air, the employer must estimate whether any employee is exposed to concentrations above the "action level." He must make a written initial determi nation of his findings. Where concentrations are low, there is no need to use sophisticated sam pling or measuring instruments; but if such mea surements have been taken, they must be con sidered in the written determination. Where more than one workplace operation involves a
regulated substance, a separate written deter mination must be made for each. Any change in process or control measure that might alfcct air borne concentrations .requires that a new deter mination be made, in writing. Bi-monthly moni toring of individual work stations becomes necessary if exposure exceeds the "action level," even though the employees at those stations wear respirators; monthly measurements would be required where employee exposures exceed the permissible limit.
Relatively accurate measurements are re quired, but the employer may choose the method or equipment, with equivalent accuracy, that suits his pocketbook and his available person nel. Accuracy of the sampling method is estab lished at a confidence level of 95 percent; that is, out of a long series of measurements, 95 percent must be within 25 percent of the true value.
In keeping with good industrial hygiene practices, methods of compliance must begin with engineering or work practice controls to reduce exposures to a level at or below the per missible limit. Where these methods are insuffi cient, they must still be used but can be supple mented by the use of respirators.
Only niosh- or MESA-approved respirators may be selected for use. While different respira tors arc acceptable at various airborne concen trations or operating conditions, the employer
may always select a respirator which provides protection prescribed for higher concentrations than those present.
Fire and safety precautions in the handling and use of the regulated substances are man dated. Data on chemical and physical character istics, fire and explosion hazards, and spill, leak, and disposal procedures, are provided in Ap pendix B to each of the proposed standards.
Protective clothing and equipment are re quired, and specific procedures established for action when a regulated toxic substance comes in contact with the employee's clothing or skin. Words and phrases are defined, to ensure uni form interpretation.
For any of the substances which may cause fire or occupational hazard when spilled, proce dures for cleanup and disposal are established.
Employees must be informed of the pres ence of any of the regulated substances in the workplace, to (he extent that they wish to be informed; it is the employer's obligation only to make copies of the appropriate regulations and appendices readily available.
An annual training program must be pro vided by the employer for all employees who (a) are exposed to a regulated substance in excess of the "action level," (b) risk skin contact with a liquid or solid form of any of the 1 I toxic substances, or (c) work in areas where the regulated substances create a lire or explosion hazard. Minimum requirements for this training are established.
Different medical surveillance programs are prescribed according to the substance to which employees are exposed. For p-tert-butyltolucne and ozone, these involve preplacement and pe riodic medical examinations.
Certain recordkeeping requirements arc proposed. At the same time. osnx is actively seeking information on ways to reduce the rec ordkeeping burden on the employer, if this can be achieved without detriment to the protection of the employee.
For the period of time the employer is re quired to maintain records, access to these rec ords must be provided to employees, former employees, their representatives, and designated physicians.
Employees or their representatives must have an opportunity to observe any mandated measurement of employee exposure to a toxic substance, and specific steps arc established for effective exercise of this opportunity.
Data in the appendices are advisory in na ture and do not create additional obligations.
Public participation in consideration of these proposed additions to the standards is encouraged.
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Proposal to amend Subpart Z of Part 1910, Title 29, Code of Federal Regulations, by addition of 11 Sections
Section
Toxic Substance
CAS No.* Common Synonyms
1910.1032 p-tert-Butyltoluene
98-51-1
1 * (1,1 -Dimethylethy1) -4-methylbenzene 1 -Methyl-4-tert-Butylbenzene p-Methyl-tert-Butylbenzene TBT
1910.1033 Cumene
98-82-8
1-Methylethylbenzene Isopropylbenzene 2'PhepyIpropane Cumol
1910.1034 Ethyl benzene
100-41-4 Phenyl ethane Ethyl benzol
1910.1035 alpha-Mclhyl styrene
98-83-9 l-Methylethenylbenzene AMS Isopropenyl benzene
1910.1036 Styrene 1910.1037 Vinyl toluene
100-42-5
Ethenyl benzene
Phenylethylene Vinyl benzene Styrene monomer Styrol Styrolene Cinnamene Cinnamenol
Cinnamol
622-97-9 1-Ethenyl-4-mcthylbenzene Methyl styrene Tolyl ethylene Mixed isomers of meta- and para-Vinvl toluene
1910.1038 Cyclohexane
118-82-7 Hexahydrobenzene Hexamethylene Benzene hexahydride
1910.1039 Camphor
76-22-2 l,7,7-Trimethyl-2-oxobicvclo-(2,2,l )-heptane 2-Camphonone Synthetic camphor Gum camphor Laurel camphor
1910.1040 Mesityl oxide
141-79-7 4-Methyl-3-penten-2-one Isobutenyl methyl ketone Methyl isobutenyl ketone Isopropylidene acetone
1910.1041
5-Mct!iyI-3-heptanone
541-85-5
Ethyl sec-amyl ketone ** Ethyl amyl ketone ** EAK** Amyl ethyl ketone**
19)0.1042 Ozone
10028-15-6 ____
* Chemical Abstracts Service (CAS) Registry Number ** Commonly but incorrectly used as a synonym for this compound
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