Document jgQrJGLB9mZw24ZmNwNmEKJXO

Interoffice Communication To Corporate Safety andIndustrial Hygiene A Prom Mary Ann Chance Dat July 25, 1983 Subject OCCUPATIONAL EXPOSURE TO BENZENE RECEIVED ^ ' JUL 2 91983 OSHA has published an expedited schedule for reviewing and possibly lowering the standard for occupational exposure to benzene. A request has been made for information on effectiveness, costs, and other issues concerning achieving exposure limits of 5 ppm, 1 ppm and 0.5 ppm. The schedule In cludes a completed proposal by November, 1983, and a final rule by July 1984. An outline and a copy of the Federal Register "Request for Information" is attached. Please review these two documents and determine whether you have an Interest In submitting data and/or comments to OSHA In the areas of Information reguested. Industrial Hygiene and Toxicology, along with Legal, will coordinate comments for submittal to OSHA by Conoco. Comments are due to OSHA by August 22; please contact me by August 3 If you will participate In this effort. We will ask for comments to then be submitted by August 15 for drafting and submittal to OSHA. <2n*> Mary fam Chance Coordinator Hazard Communication Program lei Enc. 2 Distribution: Members of the Corporate Safety and Industrial Hygiene Council 0. R. Barreel, Houston A. F. Gallagher, Houston *4. J. Hall, Ph.D., Houston J. W. Hamilton, Houston E. R. Howerton, Lake Charles L. G. Hubbard, Houston W. D. Jenkins, Houston R. L. Johnson, Houston M. A. Malloy, Houston H. A. McGuire, Houston P. L. Meeks, Houston R. W. Palmer, Houeton J. L. Pettry, Houston S. F. Pitts, Lake Charles J. L. Riddle, Ph.D., Ponca City L. J. Van Zant, Ponca City C. L. Whetstone, M.D., Ponca City R. L. Wooten, Pittsburgh Extra Copies D. M. Allen, M.D., Ponca City tf. D. Broddle, Ph.D., Ponca City E. L. DeWhltt, Jr., Ph.D., Ponca City MEY-148039 Distribution Page 1 July 20, 1983 \ "OCCUPATIONAL EXPOSURE TO BENZENE" July 8, 1983 - Federal Register "Request for Information, Regulatory Schedule" Comments due; August 22, 1983 Schedule for reviewing standard: October 1983 - Placed on Regulatory Agenda November 1983 - Proposal February 1983 - Hearings June 1984 - Final rule April 14, 1983 July 1, 1983 OSHA was petitioned to issue an Emergency Temporary Standard (ETS) reducing exposures to benzene. Petition includes references to various risk assessments. Petition denied, but expedited consideration of new schedule of review.. Risk assessments: OSHA has performed two qualitative cancer risk assessments; a third is under contract. IARC (International Agency for research on Cancer) has performed one. Other Sources: Requested by OSHA* Results: Estimate an excess leukemia risk from lifetime occupational exposure to 10 ppm benzene ranging from 14-207 deaths per 1,000 workers. Regulatory analysis Is being performed on technical and economic feasibility of a new standard. Telephone survey by JRB Associates, Inc. Data collection on compliance with current standard. Completion date - September 1983. Data submitted by - August 22, 1983. OSHA requests for Information Include: l. Medical reports and epidemiologic and toxicologic studies (inhalation or absorption) completed since 1977. VEW-148040 Distribution Page 2 July 20, 1983 2. Information on current 8-hour TWA and peak level benzene exposures by occupational categories (in detail). 3. Results of quantitative risk assessments performed on the basis of epidemiologic or experimental study results. Comment on risk assessments currently published. 4. What engineering and work practice controls are available to reduce exposures and to what levels? Are there conditions where exposures cannot be reduced through engineering controls? 5. What other methods for reduction of benzene exposure are available (other than engineering controls, work practices, and sub stitutes)? 6. What respiratory protection is available? 7. What is current practice for respirator use? 8. In areas of respiratory use, could engineering controls be lnstal led? 9. Has benzene exposure decreased since 1977? 10. Are there existing OSHA standards concerning engineering controls which reduce exposure? 11. What is level of benzene in toluene, xylene, petroleum naptha, and other solvents In use? 12. Discuss airborne exposures to benzene in solvents for exclusion purposes. 13. Should some tins interval elapse before monitoring and medical surveillance becomes effective? 14.. Are there situations concerning solvents when monitoring could be kept to e minimum or eliminated? 15v Compare percent of absorption between solvents end pure benzene. 16. Discuss current use of protective clothing. 17. Discuss substitutes to benzene. 18. Discuss analytical methods for measuring below 1.0 ppm. Include costs and frequency of measurements. 19. What exposure and medical monitoring should be imposed at oil and gas production sites? 20. Describe site similarity sampling results. UEy-148041 Distribution Page 3 July 20, 1983 m-- A) 21. What are appropriate provisions for medical surveillance of ex posed workers; frequency of medical examinations? Should provisions vary with exposure levels; how? What is the current medical surveillance provided for workers exposed? 22. Describe appropriate standard provision for respirators, pro tective clothing and equipment, hygiene facilities and practices, regulated areas, maintaining records, housekeeping, employee in formation and training, labels, and signs. What form should such provisions take in a proposal? What are provisions currently employed and costs? 23. Discuss effectiveness and costs of achieving exposure limits of 5 ppm, 1 ppm, and 0.5 ppm.