Document gbbXZOp6aEngmomx1KR9vYRYV

AMERICAN OCCUPATIONAL MEDICAL ASSOCIATION 150 NORTH WACKER DRIVE CHICAGO, ILLINOIS 60606 OSHA ISSUES FINAL LEAD STANDARD REDUCING PERMISSIBLE LEVEL TO 50 ug/ m3 A final st andard for occupat ional exposure t o lead which reduces t he permissible exposure level from 200 t o 50 ug/ m3, based on an 8-hour t ime-weight ed average concent rat ion, was promulgat ed by t he Occupat ional Saf et y and Healt h Administ rat ion on November 14. The principal indust ries affect ed by t he new st andard (primary lead product ion, secondary lead product ion, lead-acid bat t ery manufact ur ing, non-ferrous foundries and lead pigment manufact uring) are given from one t o t hree years t o reach an int erim 100 ug level and from one t o t en years t o reach t he final 50 ug level. Al l ot her indust ries must at t ain t he 50 ug level wit hin one year of t he eff ect ive dat e of t he new st andard. The permissible exposure level proposed by OSHA in 1975 was 100 ug/ m3 . The lower limit of t he final st andard was based on evidence collect ed during t he public comment period and t he ext ensive public hearings on lead held in 1977, which, according t o Dr. Eula Bingham, OSHA Direct or, clearly demon strat es t hat the t oxic effect s of lead exposure are much more ext ensive t han was previously recognized. * Blood lead levels also will be used t o det ermine t he ext ent t o which workers have been exposed. Blood sampling for all employees who are exposed above t he act ion level (30 ug/ m3) for more t han 30 days pier year must be done at least every six months. For employees whose last test showed levels above 40 ug/ 100 g blood, blood sampling must be done at least every two months unt il two consecut ive samples show levels below 40 ug. Blood sampling is t o be done mont hly for each employee who has been re moved from exposure owing t o an elevat ed blood lead level. Job and wage prot ect ion against removal for medical reasons is provided in the new lead st andard, t he s first healt h st andard issued by OSHA cont aining such provision. It specif ies t hat workers wit h elevat ed blood levels must be placed in ot her unexposed j obs at no loss in pay, seniorit y, or ot her employment status and right s unt il blood lead levels fall to accept able limit s. The cont ent of medical examinat ions t o be made available under t he st andard include t he following: (1) A det ailed work hist ory and a medical hist ory, wit h part icular at t ent ion t o past lead exposure (occu pat ional and non-occupat ional), personal habit s, and past gast roint est inal, hemat ologic, renal, cardio vascular, reproduct ive and neurological problems; (2) a t horough physical examinat ion, wit h part icular at t ent ion t o t eet h, gums, hemat ologic, gast roint est inal, renal, cardiovascular, and neurological systems, wit h pulmonary status being evaluat ed if respirat ory prot ect ion is t o be used; (3) a blood pressure measure ment; (4) a blood sample and analysis which det ermines blood lead level, hemoglobin and hemat ocrit det erminat ions, red cell indices, and examinat ion of peripheral smear morphology, zi nc prot oporphyrin, blood urea nit rogen, and serum creat inine; (5) a rout ine urinalysis wit h microscopic examinat ion; and (6) any laborat ory or ot her test which t he examining physician deems necessary by sound medical pract ice Whil e the new st andard is scheduled t o become ef f ect ive February 1, 1979, both labor and indust ry wast ed no time in f iling legal challenges t o t he regulat ion. The Unit ed St eelworkers of America f iled In Philadelphia wit h t he U. S. Court of Appeals for the Third Circuit and t he Lead Indust ries Associat ion f iled In New Orleans wit h the Fift h Circuit Court of Appeals. The St eelworkers say t he st andard is not st rict enough, while LIA stresses t hat t he new st andard pays no heed t o economic or t echnical realit y or t o t he inf lat ionary impact which it will have. LIA also condemns OSHA's insist ence on ret aining an environment al exposure limit which is based on t he now discredit ed assumpt ion t hat a worker's bloodlead level can be correlat ed wit h and predict ed from part icular occupat ional air-lead levels. PANEL OF EXPERTS REPORTS ON REVIEW OF BERYLLIUM STUDIES The panel of independent consult ant s convened by the Surgeon General Julius Richmond and William Foege, Direct or of t he Cent er for Disease Cont rol, t o review dat a on the effect s of beryllium exposure has concluded t hat animal st udies are credible in showing beryllium carcinogenicit y in at least two species. This was one of t hree quest ions t he panel was asked t o answer. However, comment ing on t he st udies report ed, the expert s said that "many lack rigorous analysis, are oft en poorly cont rolled, suffer from inconsist ent prot ocol and exposure periods, and frequent ly lack st at ist ical j ust if icat ion. " They st rongly recommended that addit ional well cont rolled st udies of t he effect s of inhalat ion of beryllium compounds and beryllium alloys in animals be performed in order t o generat e dat a relat ing t o lat ency, part icle size, the effect s of copper alloys, clearance, and dose response. There are insuf ficient data available t o answer t he second quest ion, "Is beryllium copper all oy a car ci nogen?" according t o t he consensus report of t he panel. They recommend t hat appropriat e st udies be undert aken to det ermine t he nat ure and ext ent of worker exposures t o t his all oy and t hat it be tested as a carcinogen. Finally, t he panel found t hat t he epidemiological evidence is "suggest ive" t hat beryllium is a carcino gen in man. They do not believe t he evidence at t his t ime is more t han suggest ive because alt ernat ive explanat ions for the posit ive findings have not been def init ely excluded. "Likewise, " t hey added, "t he t hree reports (Wagoner, et al . , 1978; Mancuso, 1978; and Infant e, ?t al . , 1978) showing a posit ive st at ist ical associat ion bet ween beryllium exposure and human lung cancer are unpublished draft s, each of which is likely to require some revision aft er j ournal peer review prior to publ icat ion. " (. . Based on t heir f indings, t he panel concluded t hat beryllium should be considered a suspect carcinogen for exposed workers. Based on t his report, Secret ary of Healt h, Educat ion and Welf are, Joseph A. Calif ano, Jr . , wrot e Ray Marshall, Secret ary of Labor on November 7 recommending t hat t he Occupa t ional Saf et y and Healt h Administ rat ion proceed t o set st andards t hat limit exposure t o beryllium in the w or kpl ace. . OSHA REQUESTS INFORMATION O N REGULATION OF OCCUPATIONAL 0<POSURE TO PESTICIDES Is t he generic approach appropriat e for regulat ion of employee exposure in pest icide manufact uring and formulat ing f aci l i t i es? Should permissible exposure limits be developed for t he subst ances not current ly regul at ed? Are t here any pest icides in widespread product ion that are not current ly regul at ed? These and ot her quest ions have been raised by t he Occupat ional Saf et y and Healt h Administ rat ion wit h regard t o t he recommendat ions cont ained in t he 429-page pest icide crit eria document recent ly t ransmit t ed to OSHA by t he Nat ional Inst it ut e for Occupat ional Saf et y and Healt h. In t he November 24 issue of t he Federal Regist er, OSHA published a formal request for comments and informat ion, posing many quest ions wit h regard t o specif ic NIOSH recommendat ions. In t he recommended st andard, NIOSH did not include environment al (workplace air) limit s, since, ac cording t o NIOSH, it would t ake years t o est ablish scient if ically valid environment al limit s for approxi mat ely 1, 500 pest icides. Consequent ly, the Agency recommends reliance on engineering cont rols, work pract ices, medical examinat ions, and educat ion of employers and employees as t he first step in prot ec-