NEVER follow an OSHA guideline when there is anything else to look at. In 1989 OSHA updated about 400 of their PELs. Industry coalitions took OSHA to court and got a ruling that required OSHA to provide complete economic and environmental impact studies for each PEL before they could change it. There's not enough trees on the planet to make the paper for doing that for 400 PELs. And OSHA would have to devote full time to the job for an estimated 20 years to get all that done and approved, at which time those new PELs also would be outdated.
OSHA gave up and the majority of the OSHA PELs now are at the same levels they were in 1971 when the agency was formed (there are only six updated PELS and the last one was done when a coalition of unions took OSHA to court and forced them to set a standard for chromium compounds that would protect their workers).
OSHA has stated clearly that their own PELs are not protective enough. I use ACGIH TLVs, NIOSH RELs and the German MAKs when I can get them. And I keep a copy of the PELs that OSHA set in 1989 around just to show where they would be set today if OSHA could have prevailed.
The new OSHA head, David Michaels, says he will try another strategy soon to try to update the PELs. Not much chance in this political climate. Sheesh.
In a message dated 12/3/2010 4:52:07 PM Eastern Standard Time, jimtung**At_Symbol_Here**GMAIL.COM writes:
When the NIOSH pocket guide has different permissible limits (NIOSH versus OSHA), which is the better one to follow?
For example, benzene's limit for NIOSH is 0.1 ppm (10 hr workday), while OSHA's limit is 1 ppm (8 hour workday.)
Why the difference? From a legal perspective, which is a better choice?
Thanks in advance for any advice you might give; obviously, any advice people might give is non-binding, you're not responsible, legal mumbo-jumbo, blah, blah.
Cheers, Jim Tung
Lead Hazardous Waste Coordinator
Obiter Research LLC
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