Document rEOD0vqyJq19K27G7oEdkj4E

236 September, 1956 exist.* al which to measure atmospheric con lead to unfortunate problems of administra centration before designing safeguards. The tion to which brief reference may be made. similarity of engineering standards for the Under the constitutions of the various in-plant situation to emission standards for states and the powers grunted to state De atmospheric pollution control is noted. partments of Health and state Departments of Labor, there exists adequate authority Prepared Discussion for such departments to effectively control any hazardous condition injurious to health. As a practical matter, there is no THEODORC C WATERS. I LB. legal need for the adoption of codes prescrib Baltimore*. Maryland ing maximum allowable concentrations. It is fair to stale that stale Departments of Health mid state Departments of Libor 8 This comment and discussion of the ex administering divisions of industrial hy cellent paper presented by Dr. Brandt giene have enjoyed the confidence of the will be directed to the legal aspects of thepublic, including both management and r.`>; application of threshold limits in the form labor, and our several state departments of maximum allowable concentrations for have been and are doing excellent jobs in the control of air contamination. the administration of their affairs. There May 1 identify myself as one who has fore, the use of maximum allowable concen screed ns counsel for industrial organiza trations should be in the until re of serv tions; and while my views may In* prejudiced ing as a guide to industry with particular on their behalf. 1 feel that the industrial reference to engineering standards. Indus point of view is impoitartt in onr discussion try lias and will continue to seek the of this matter. advice of proper state departments to con It is needless to say that today industry is trol hazardous conditions effectively, and prepared ami wishes to accept full responsi the desired objectives will be obtained bility for the control of potential hazards incident to employment. Simply stated, it is good business both from the financial through education and dissemination of in formation through the cooperation between state divisions of industrial hygiene and standpoint and also in the promotion of industry rather than the attempted enforce industrial relationships for employers to ment of a given code as a matter of law. concern themselves with the protection of Dr. Brandt and Mr. Stern have discussed employees from all types of industrial in In detail the practical uses of threshold lim juries, be they accidental or resulting from its with the purpose of eliminating or con occupational disease. The ultimate cost of trolling occupational hazards. With all of compensation for such injuries may well ex the information presently available to ceed the cost resulting from installation of science, it is seriously to be questioned effective methods for engineering and medi whether the present schedule of recom cal control, aside Hum the fact that the em mended maximum allowances of roiicenlrn- ployer's relation to his employees is pro lion* are .scientifically correct. True, they moted when employees know that the em represent the best thinking of those scien ployer is doing everything practical to effect tists who have studied the problem; how protection. ever, it is a fact that from day to day, indus Question arises to the propriety and ad trial processes are changing, new chemical visability of the adoption of codes of in compounds are coming into commercial use, dustrial hygiene defining maximum allow and tomorrow some new problem may be able concentrations of toxic materials. The presented to industry and to public ad word "code" is defined as follows: "A ministrative agencies entirely different from body of law established by the legislative any that may have been presented before. authority of the state, and designed to regu Industry welcomes technical information late completely, so far as a statute may, the with, respect to the existence of occupational subject to which it relates/' The adoption of hazards. They will continue to welcome codes having the full force and effect of law technical advice as to practical methods of is unnecessary, inadvisable, and may well control. It must be remembered that in-