Choosing Which PEL s to Update Franklin E. Mirer, PhD, CIH Professor, EOHS Program School of Urban Public Health at Hunter College CUNY School of

Transcription

1 Choosing Which PEL s to Update Franklin E. Mirer, PhD, CIH Professor, EOHS Program School of Urban Public Health at Hunter College CUNY School of Public Health NY Metro AIHA Trisectional Princeton, NY December, 2014 fmirer@hunter.cuny.edu

2 Learning Objectives (1): State the evidence for and against: Chronic disease from chemical exposures is a greater cause of occupational mortality than traumatic injury Exposure limits are the optimal method for controlling chemical hazards Science exists to set protective limits for many chemicals Enforcement can be applied to workplaces in compliance with PEL s that don t protect

3 Learning Objectives (2): A priority should be given to agents for which exposures exceed health based limits Regulating these priority substances is within resources Significant and important exposures fall out of a PEL update type process

4 How Important are Chemical Exposures In Our Workplaces?

5 90% of Known Work Related Mortality is Chronic Disease Arising From Long Term Chemical Exposure

6 Ratio of Illness to Injury Mortality Injury : 6,200 per year Illness : 49,000 per year, range is 26,000 to 72,000 Ratio Illness to Injury: Low = 4.2 Best = 7.9 High = 11.6 Fraction of total which is Illness: Low = 81% Best = 89% High = 92% Steenland, (2003). "Dying for work: The magnitude of US mortality from selected causes of death associated with occupation." Am J Ind Med 43(5):

7 Controlling Chemical Exposures

8 Lord Kelvin When you can measure what you are speaking about, and express it in numbers, you know something about it, when you cannot express it in numbers, your knowledge is of a meager and unsatisfactory kind; it may be the beginning of knowledge, but you have scarcely, in your thoughts advanced to the stage of science.

9 TLV PEL list as a Boundary Object

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11 Where do we start with controlling exposures? Any control scheme should be based on an evaluation criterion PEL, REL, OEL, TLV, RfC, MRL

12 There are known knowns; there are things we know that we know. There are known unknowns; that is to say, there are things that we now know we don t know But there are also unknown unknowns; there are things we do not know we don t know.

13 Knowledge Distribution Known Known Unknown Known Known Unknown Unknown Unknown

14 Alternatives to PEL s

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16 General Duty Clause Takes Precedence over Specific OSHA Standards: "If an employer knows a particular safety standard is inadequate to protect his workers against the specific hazard it is intended to address, or that the conditions of his place of employment are such that the safety standard will not adequately deal with the hazards to which his employees are exposed, he has a duty under section 5(a)(1) to take whatever measures may be required by the Act, over and above those mandated by the safety standard, to safeguard his workers." D.C. Court of Appeals, UAW v. General Dynamics 13 OHSC 1201, April 14, 1987

17 Making A Difference: Identify agents for which prevailing exposure levels are known to pose a significant risk

18 Lists of Lists OSHA, CalOSHA, REL, TLV, MAK, WEEL 473 Agents with PEL s (includes 6(b) chemicals) 484 Agents with OEL s but no PEL s 16 Agents with 6(b) standards Source: NIOSH

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20 Advanced Authoritative Risk Assessments EPA IRIS 540 Substances Reference Concentrations (RfC) Cancer Slope Factors ATSDR 399 Substances MRL s Acute Intermediate Chronic

21 OSHA PEL Chat

22 125 Comments

23 Working List: Acetone Anesthetic gases 1-bromopropane Carbon monoxide Chemotherapeutic agents Diesel exhaust Glutaraldehyde Isocyanates Manganese Mercury N-hexane Perchloroethylene Styrene Toluene Welding fumes

24 Working List: Acetone Anesthetic gases 1-bromopropane Carbon monoxide Chemotherapeutic agents Diesel exhaust Glutaraldehyde Isocyanates Manganese Mercury N-hexane Perchloroethylene Styrene Toluene Welding fumes

25 Working List: Acetone Anesthetic gases 1-bromopropane Carbon monoxide Chemotherapeutic agents Diesel exhaust Glutaraldehyde Isocyanates Manganese Mercury N-hexane Perchloroethylene Styrene Toluene Welding fumes

26 Working List: Acetone Anesthetic gases 1-bromopropane Carbon monoxide Chemotherapeutic agents Diesel exhaust Glutaraldehyde Isocyanates Manganese Mercury N-hexane Perchloroethylene Styrene Toluene Welding fumes

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28 Working List: Acetone Anesthetic gases 1-bromopropane Carbon monoxide Chemotherapeutic agents Diesel exhaust Glutaraldehyde Isocyanates Manganese Mercury N-hexane Perchloroethylene Styrene Toluene Welding fumes

29 What levels of exposure do we have the evidence to limit exposure to?

30 Toluene (OSHA sampling page)

31 Manganese Fume (mg/m 3 ) OSHA PEL 5 NIOSH REL- 1 ACGIH TLV CalOSHA PEL EPA RfC- 5 x 10-5 ATSDR MRL (chronic)

32 Silica

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34 OEL for Silica defined in 1927 Public Health Reports (Bulletin 187)

35 OSHA Estimates of Fatal Disease Risks from silica, deaths per 1,000 Current general industry PEL (0.1 mg/m 3 ) Proposed PEL (0.05 mg/m 3 ) Action Level (0.025 mg/m 3 Lung Cancer: (10-cohort pooled analysis) Silicosis NMRD w/o Silicosis

36 Left off the Lists: Diesel Particulate Matter Particles NOC Metalworking fluids Wood dust

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