Barret, That's a pretty good summary of reasons why not to use the PELs. The real crux of the matter is a 1992 court decision in a case brought by a coalition of industries after OSHA updated 416 PELs through the regulatory process. This court decision rescinded all of those PELs, reset them to the 1971 values, and makes it impossible for OSHA to set new PELs without the massive amount of work it takes to present a two complete analyses for each PEL: one analysis of the environmental impact, and the other of the economic impact. That means OSHA must find out who all the users of each chemical are and what it will cost each to meet the new standards plus the number of workers who will not get sick or die to balance the cost of addressing those workers' healthcare against the cost to the industry.
There are not enough trees on the planet to create the paper it would take to do this for the 416 PELs OSHA had tried to update. Each PEL will take years to do. That's when only the beryllium, chromium, and 14 other PELs of their 400+ PELs have been updated since 1971. And that is why there are another 200+ substances for which there are TLVs that OSHA has no standards for at all.
I work internationally, and in the 1970s, I was so proud of the US because we were the first to institute worker air quality regulations. Recently in Amsterdam at a training of art conservators from several EU nations, I had to apologize for our standards because there's are better. We should all be ashamed of a country that allows industry to place their economic issues far above the lives and health of their workers.
In a message dated 2/2/2012 3:53:10 PM Eastern Standard Time, rweeks**At_Symbol_Here**LANL.GOV writes:
The best reason for not going w/the OSHA values is that they are so often incorrect and unsafe. A case in point is the OSHA PEL for beryllium. In September of 1999 OSHA published awareness information stating that the PEL for beryllium was not protective of the American worker. The PEL value at that time was 2.0 micrograms per cubic meter, i.e., the same value as it is today. The process of getting something changed in OSHA involves not only epidemiological data but also economic factors. When economic factors are considered, changing a PEL can sometimes take decades=E2=80=A6yes, decades. On the other hand, NIOSH can evaluate epidemiological data and establish a value based on the epidemiological data and not be burdened with the economic factors. For this reason the NIOSH value is generally more up to date and more protective of the American worker than is the OSHA value. In the case of the formaldehyde OELs,0 .75 /0.016 = 46.9, nearly a fifty fold lower concentration using the NIOSH value. Also, the NIOSH value states that formaldehyde is a carcinogen and OSHA does not give this warning.
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