Date: Sat, 4 Dec 2010 18:52:46 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
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From: "Wright, Mike" <mwright**At_Symbol_Here**USW.ORG>
Subject: Re: OHSA/NIOSH Permissible limits
In-Reply-To: A<140b67.1bd19707.3a2bb072**At_Symbol_Here**>

In answer to your question, there is an OSHA standard, called “Hazard Communication,” that requires chemical labeling and accessible safety data sheets, including ACGIH TLVs. (OSHA has proposed to strengthen by adopting a stricter and more comprehensible global system in use in Europe and other areas.) Unionized workplaces can use the standard to push for improvements. Non-union workers are often scared to speak out, but at least they have access if their employer follows the law.  

Art students are not employees so they are not covered by the standard. But since there are employees who work in the school – janitors, technicians, even the faculty itself – the labels and data sheets should be available.

I was involved in a similar situation some time ago. I reminded the school that there is a very active tort bar, and that if a student was injured by a material that the school knew was dangerous, and the school had withheld the information, they were looking at millions in legal fees and damages, not to mention losing accreditation. At that point they seemed to rediscover their conscience, and put a pretty good program in place.

Mike Wright

Michael J. Wright

Director of Health, Safety and Environment

United Steelworkers

(412) 562-2580 work

(412) 370-0105 cell

(412) 562-2584 fax



From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of ACTSNYC**At_Symbol_Here**CS.COM
Sent: Saturday, December 04, 2010 9:56 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] OHSA/NIOSH Permissible limits

Chris,  That's a good short list.  But I'm such an idealist, I hope that on occasion a student asks:  "If the TLVs are based only on health factors, what other factors are being used by OSHA to set PELs?"

And if those other factors are economic and feasibility factors, are US workers really told that, as a condition of employment, they can be exposed to levels determined by ACGIH, NIOSH and other agencies to be unhealthy?  And is that hazard information provided in enough depth to enable workers to provide informed consent? 

The same type of problem occurs in universities when faculty doesn't fully inform and train their students.

I recently visited a school that will remain nameless.  The EH&S people are planning to finally start hazard communication training program in the art department after an incident--the usual reason they call me.  The EH&S people, as usual, were not very familiar with conditions in art and suitably shocked when they saw them.  But it was the comments of the art faculty that that email is about.  They told the EH&S people that they must not train the students about the hazards or they might lose enrollment.

So in schools, I guess we can add "keeping your enrollment high so your job is secure" as yet another factor that should be considered in setting exposure levels and providing training.


In a message dated 12/4/2010 4:44:08 AM Eastern Standard Time, cekohler**At_Symbol_Here**INDIANA.EDU writes:

Here is a nice little summary I use in class. For worker safety it always better to use the lower thresholds but the OSHA thresholds are the legally enforceable ones.


OSHA (or state established) exposure limits are law:

PEL = Permissible Exposure Limits (29 CFR 1910.1000)

•Based on health factors, economic and technical feasibility.
•TWA = 8 hour time weighted average
•STEL = 15 minute Short Term Exposure Limit
•C = Ceiling Concentration must never be exceeded.
Other exposure limits are guidelines or BMPs:

NIOSH - National  Institute for Occupational Safety and Health

•Based on chemical, medical, biological, engineering, trade and other information.

•REL = Recommended Exposure Limits (10 hr TWA, used for recommending new exposure limits to OSHA)

•IDLH = Immediately Dangerous to Life and Health (based on 30 min. exposure but must exit)

ACGIH = American Conference of Governmental Industrial Hygienists

•Based on health factors only.

•TLV = Threshold Limit Value (8 hour TLV-TWA, TLV-STEL, TLV-C, they also establish “Excursion Limits” commonly used in emergency response activities = 3 to 5 x TLV for 30 min.)

•BEI = Biological Exposure Indices (mg/l of  body fluid to be used in biological monitoring)

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