BACKGROUND:
In 1993, the International Union, United Automobile, Aerospace & Agricultural Implement
Workers of America (UAW) petitioned OSHA to take emergency regulatory action to protect
workers from the risks of occupational cancers and respiratory illnesses due to exposure to
metalworking fluids. Subsequently OSHA's Priority Planning Process report then identified
exposure to metalworking fluids as worthy of Agency action. The Assistant Secretary for OSHA
asked the National Advisory Committee on Occupational Safety and Health (NACOSH) for
recommendations on how to proceed. NACOSH recommended that OSHA form a Standards
Advisory Committee (SAC) to address the issues relating to occupational exposure to
metalworking fluids. The Secretary of Labor signed the charter establishing this SAC on August
28, 1997. The Advisory Committee was comprised of representatives from unions, university and
NIOSH public health officials, and large and small employers from affected industries. The
Standards Advisory Committee submitted their Final Report to Assistant Secretary Charles
Jeffress in July, 1999. The following is a Summary submitted as part of this Final Report.
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SUMMARY
FINAL REPORT
of the
OSHA METALWORKING FLUIDS
STANDARDS ADVISORY COMMITTEE
Submitted by
Dr. Maura J. Sheehan, C.I.H
Chairperson
7/15/99
SUMMARY of the
RECOMMENDATIONS
of the
OSHA METALWORKING FLUIDS
STANDARDS ADVISORY COMMITTEE
The OSHA Metalworking Fluids Standards Advisory Committee recommends
that OSHA act to mitigate the adverse health effects associated with exposure to
metalworking fluids (MWFs). This decision is based on the demonstrated health
effects: asthma, hypersensitivity pneumonitis, other respiratory disorders and
dermatitis. In the opinion of the committee, each of these health effects is a material
impairment of health, presents a significant risk, and occurs throughout the industry.
The committee also recognizes that there are other health conditions, including cancer,
related to MWF exposure for which the evidence is still evolving. The details of the
committee's deliberations about health related issues can be found in Chapters Two
and Eight of this report.
The committee supports the use of a defined occupational exposure limit and
unanimously supports the use of systems management to control exposure. The
committee unanimously recommends that the scope of any OSHA action include fluids
used in the machining environment including the operations of cutting, machining,
grinding and honing. While the committee recommends that the scope be limited to
these operations and their fluids, the exclusion of other metalworking fluids or related
processes or environments does not imply the lack of a potential problem in these
related fluids, processes or environments. Further information about the scope of any
OSHA action can be found in Chapter One of this report.
The committee recommends that OSHA promulgate a comprehensive 6(b)
standard to protect employees from the adverse effects of MWFs and material
impairment of health. Dissenting minority opinions to this recommendation that
address non-regulatory alternatives are summarized in Attachment #1. The
deliberations of the committee and majority and minority views on specific issues are
stated in the body of the report. Specific discussions of OSHA actions are in Chapter
Five of this report.
The committee recommends that a standard for MWFs should include a
permissible exposure limit (PEL), systems management, medical surveillance and
training. This approach for a standard should control exposure and achieve a
meaningful reduction of disease.
The committee recommends a new 8 hour time weighted average PEL of 0.4
mg/m3 thoracic particulate (0.5 mg/m3 "total" particulate). The scientific rationale for the
recommended PEL is based on studies of asthma and diminished lung function. This
research is provided in the NIOSH Criteria Document, and in the record and report of
this committee. Current OSHA regulations and existing consensus standards do not
address the exposures that occur in the contemporary MWF environment. The TLVR
for mineral oil mist and the Particulates Not Otherwise Classified (PNOC) PEL are not
appropriate, or adequate for currently used MWFs and the complex MWF environment.
Additional information on the deliberations about an exposure limit is provided in
Chapters Two and Five of this report.
In addition to a PEL, the committee recommends systems management of the
MWF environment to further protect employee health. Systems management includes
a comprehensive programmatic approach with enclosure, ventilation, fluid management
and other actions to control exposure and minimize contact with the fluid. Systems
management discussions are found in Chapter Three, and the committee's Best
Practice for Systems Management is in Chapter Six of this report.
The committee recommends an active medical surveillance program as an
essential component of the proposed 6(b) standard. Since there is evidence of
adverse health effects below the PEL, medical surveillance provides a safety net for
those individuals exposed to MWFs. Medical surveillance allows early detection of
adverse health effects, and leads to better health outcomes. Key characteristics of an
effective medical surveillance program are detailed in Chapter Eight of this report.
The committee notes that training and outreach activities are essential
components of any action involving MWFs. Training of employees about MWFs is
essential and part of OSHA's role. As noted in Chapter Nine of this report, other
individuals need better information to effect the changes needed in workplaces using
MWFs.
The recommended PEL, a systems management approach, active medical
surveillance and training are technologically and economically feasible for employers
affected by this recommendation. While the recommendations are technologically and
economically feasible, the committee recognizes that the recommendations are
substantial and will require a phase in period. The details of the discussions and
evidence reviewed about technological and economic feasibility are found in Chapters
Three and Four of this report.
Because the problem is clearly recognized, and feasible solutions are identified,
the committee recommends that OSHA promulgate this standard with all deliberate
speed. More than a million workers are exposed to MWFs, urgent action is needed.
SUMMARY of the
DELIBERATIONS
of the
OSHA METALWORKING FLUIDS
STANDARDS ADVISORY COMMITTEE
Committee Organization and Activities
The OSHA Metalworking Fluids Standards Advisory Committee (MWFSAC) was
formed on 8/28/97, the date the committee's charter was signed by the Secretary of
Labor. The 15 members and 2 alternates of the committee are listed in Attachment #2
of this report. Alternates were included in all discussions, but did not vote. The
activities of the committee are defined in the charter which is discussed in Chapter One
of this report, and is found in Attachment # 3. All deliberations were conducted at ten
public meetings throughout the United States. Work groups made up of committee
members and alternates visited work sites and gathered other information for the
committee to review. This final report is the product of the committee's deliberations.
This committee report is submitted by the committee chairperson to the Assistant
Secretary of Labor for OSHA on July 16,1999, seven days after the adjournment of the
last meeting of the committee. The information reviewed, concerns noted, views
expressed, and decisions made by the committee are included in this report.
Scope of any OSHA Action
The committee did not vote on the scope of the fluids but a general consensus
developed. The committee recommends that the scope of any OSHA action includes
that subset of metalworking fluids that are also known as metal removal fluids. These
fluids are those used in traditional operations on metal including cutting, machining,
grinding and honing. The fluids and the environment they are in have to be considered
together due to the changing nature of the fluids as they are used in their environment.
The rationale for this approach includes: the need to clearly differentiate the
types of fluids involved, and the knowledge base available for health effects, exposure
levels, exposure assessment methods and/or control. The exclusion of any related
fluid, process or environment does not imply the lack of a potential problem in these
related fluids, processes or environments.
Health Issues
Dermatitis
The majority opinion of the committee is that dermatitis is known to be
associated with exposure to MWFs. Thirteen (13) members held this majority opinion.
Members cited their own experiences: working with individuals who had dermatitis,
treating employees with dermatitis, and observations at a MWF plant visited by the
work groups. In addition, presentations by dermatologists, Adams and Lusniak, and
machinist, Gauthier; the NIOSH Criteria Document and other literature; and letters sent
by small business were noted as evidence. Dermatitis from MWF is a material
impairment of health.
The minority opinion of the committee was the evidence on dermatitis was
equivocal. Two (2) members, Burch and Howell, held this minority opinion. These
members noted their own experiences and stated that dermatitis is associated with
poorly managed fluids. Manufacturers test and produce fluids that when new, generally
do not cause dermatitis.
In discussion, two members, Teitelbaum and Mirer noted that all MWFs can
cause dermatitis. Two other members, Day and McGee explained that all MWF plants
they have been in had workers with dermatitis. Two members, Cox and Burch stated
that although there are dermatitis problems, these problems are controllable.
Acute and Chronic Respiratory Effects
The majority opinion of the committee was that acute and chronic respiratory
effects are known to be associated with exposure to MWFs. Thirteen (13) members
held this majority opinion. Members cited the epidemiological studies, the limited
toxicology studies and their own experiences: in plants, in discussions with workers and
in clinical practice. Presentations by Rose, Fennelly, Eisen, Hodgson, Fennelly's
patient, the NIOSH Criteria Document and papers by Kennedy were noted as additional
evidence. Data from Wegman (Wegman,1998), and Rosenman (1998) were cited.
One member, White, stated that there was some evidence to support the association of
acute and chronic respiratory effects and MWFs. Another member, Cox indicated that
there was no evidence in small plants, although there was in large ones.
The minority opinion of the committee was the evidence was equivocal. One (1)
member, Howell, held this minority opinion. Concerns were expressed about the
categorization of fluids, and other confounders in the studies. Risk ratios were close to
one, making them vulnerable to confounders. The relevance of some of the health
endpoints was questioned.
One member, Burch, had no comment.
In discussions, two members, O'Brien and Sheehan, explained that the effects
were associated with end-use fluids. One member, McGee, noted that there was more
evidence for acute effects than chronic effects. One member, Mirer, explained that HP
is more associated with in-use water- based fluids and asthma is associated with all
MWFs. This same member, Mirer, viewed that material impairment of health related to
respiratory problems is more associated with water-based fluids.
Cancer
The committee addressed skin cancer and cancer at other sites as separate
issues. The opinions were separated into evaluating "old formulations" versus "current
formulations".
Skin Cancer
The majority opinion was that skin cancer is known to be associated with
exposure to old formulations of MWFs. Ten (10) members held this majority opinion.
The opinions were mixed for current formulations of MWFs. White believed that old
formulations were a problem. Two members, Lick and Teitelbaum, believed there was
no evidence for current formulations. Three members Sheehan, Mirer, and Frederick,
viewed evidence for current fluids as equivocal. One member, Anderson, thought it
was reasonably anticipated that there was evidence for current fluids. Three members,
Wegman, Newman, and Day believed there was known evidence for old and current
formulations. Chapter Five of the NIOSH Criteria Document was cited. Issues such as
the difficulty of assessing the effects of current exposure due to the latency period and
the possible presence of co-carcinogens and promoters were noted.
The minority opinion was that the evidence was equivocal for old formulations.
Three (3) members, Burch, Cox, and Howell held this minority opinion. As noted
above, the opinions for current fluids were mixed. The members who presented the
minority view on the older formulations believed there was no evidence for current
formulations.
Two members, O'Brien and White did not think they had adequate information to
make a decision on the issue of skin cancer.
Cancer at Other Sites
The majority opinion was that old formulations of MWFs are known to cause cancer
at various sites. Ten (10) members held this majority opinion. Epidemiological studies,
MSDSs, and the NIOSH Criteria Document were cited.
The minority opinion was that the information on the older formulations was
equivocal. Three (3) members, Burch, Howell, and Lick held this minority opinion. The
inconsistencies among the epidemiological studies regarding sites were noted for a
rationale.
Two members, Cox and White had no opinion.
The committee was split on the issue of cancer related to current formulations of
MWFs. Four members, O'Brien, Lick, Teitelbaum, and Frederick viewed that evidence
was equivocal for current formulations. Four members, Day, Newman, Sheehan, and
Anderson, viewed the evidence as reasonably anticipating cancer associated with
current fluids. Three members, Howell, Cox, and Burch thought there was no evidence
that currently formulated MWFs cause cancer. Three members, Wegman, Mirer, and
McGee noted that prudence dictates that we view current formulations as carcinogenic,
and one, White, had no opinion. Latency periods, and reductions in nitrosamines and
PAHs were noted as a rationale and concern.
Technological Feasibility
Permissible Exposure Limit (PEL)
The majority viewed that the recommended PEL was technically feasible.
Twelve (12) members held this majority opinion. Day, Teitelbaum, Mirer and O'Brien
cited their own experiences, presentations before the committee, site visits, the
machine tool builders discussion and data provided by industry as a basis for this
decision. The downward trend in exposures with time, the evaluation of controls study
done by Hands et al, and the NIOSH Small Business study were also noted by O'Brien
as a rationale. O'Brien and Mirer urged more effective use of general ventilation to
achieve the targeted PEL. O'Brien noted that straight fluids are more difficult to control
and opined that anti-mist additives may be helpful to control exposure in small
business.
The minority opinion was that although the PEL could be achieved with new
equipment, it could not be with old, existing equipment. One (1) member, Howell, held this
minority opinion.
Burch focused on the technical feasibility of measuring exposures at the PEL
and thought it was feasible. He did not have enough information to determine the
feasibility of a PEL. Cox could not separate technical feasibility from economic
feasibility, noting that some companies would be more able than others to comply
based on their financial condition.
Systems Management
All 15 members viewed that systems management was technically feasible.
Members cited the presentations, site visits and their own experiences as contributing
to this decision.
Medical Surveillance
The majority explained that medical surveillance, as defined by the best
practices document prepared by the committee, was technically feasible. Twelve (12)
members held this majority opinion. Newman based this decision on his own
experience developing programs for businesses. Sheehan cited the long track record
for these types of tests. McGee urged training of workers about medical surveillance.
The minority opinion on the technical feasibility of medical surveillance was that
the program specified in the best practices document prepared by the committee was
not technically feasible. Three (3) members, Burch, Cox, and Howell held this minority
opinion.
Economic Feasibility
Permissible Exposure Limit (PEL)
The majority viewed that achieving the PEL was economically feasible. Twelve
(12) members held this majority opinion. O'Brien cited data submitted by Ford and an
Office of Technology Assessment report. Mirer viewed the Ford data as a high
estimate, noting that many exposures at Ford were below 0.5 mg/m3. Mirer stated that
small companies would have lower ventilation system costs and that all companies
would benefit from less expensive improvements in general ventilation. Sheehan noted
that not every work station has to be improved for the overall exposure to be reduced
and urged a focus on the worst machines. Day explained that companies find the
money when OSHA puts pressure on them. Lick and White stated that achieving the
PEL was economically feasible with enough time allowed to phase in changes.
The minority stated that achieving the PEL would be very expensive and
economically infeasible. Two (2) members, Burch and Cox held this minority opinion.
Burch cited the evidence provided by Ford (Henry, 1998) and the American Automobile
Manufacturer's Association (Felinski,1998).
There was one abstention, Howell, who noted that there was not adequate
information to reach a decision on the question of the economic feasibility of a PEL.
In discussions, White stated that the costs could be on par with the proposed
ergonomics standard. Cox cited small business problems with cash flow and tax laws
related to regulatory compliance. Lick estimated that ventilation costs for some small
businesses would be a few thousand dollars. There was general agreement that more
information is needed on this issue.
Systems Management
All 15 members viewed that systems management was economically feasible.
The committee stated that it was economically infeasible not to do systems
management. O'Brien cited clear economic benefits of systems management including:
reduced painting, reduced accidents due to slippery surfaces, and improved retention
of employees. White cited Gauthier's presentation as showing cost effectiveness of
systems management. Mirer noted that systems management may enhance exposure
reduction and provide jobs.
Medical Surveillance
The majority thought that medical surveillance as outlined in the best practices
document was economically feasible with some limitations. Twelve (12) members held
this majority opinion. Members noted the per test costs, and their own experiences with
medical surveillance as rationale. White cautioned that his decision was based on the
high threshold defined for economic feasibility.
The minority stated that the medical surveillance as outlined in the best practices
document was not economically feasible. Three (3) members, Burch, Howell, and Cox
held this minority opinion. Burch noted that the cost would depend on the level of detail
required. Howell refined his minority opinion that some degree of medical surveillance
was economically feasible but not the one stated in Chapter Eight of this committee
report.
The need for a Permissible Exposure Limit, PEL.
The majority opinion was that a MWF PEL as an 8 hour time weighted average
was needed. Twelve (12) members held this majority opinion. O'Brien cited the
inappropriateness of the TLV for mineral oil mist with no additives. This TLV was
based on the health effect of lipid pneumonia and did not represent MWFs used today.
Wegman was concerned that the current Particulates Not Otherwise Classified (PNOC)
designation was inadequate. Newman cited the number of health effects that cause
material impairment of health, burdening the American worker.
The minority opinion was that OSHA needed to prove by a risk assessment that
a new PEL was needed. Three (3) members, Cox, Burch, and Howell held this minority
opinion. Cox noted that a PEL probably was needed. Howell thought there should be
a lower exposure guide for metal removal fluid mist. The lack of significant risk and the
linkage of many problems with operational factors and not MWFs were given as
rationale. A voluntary approach was stressed.
Recommended PEL
The majority viewed that the evidence pointed to 0.5 mg/m3 "total" particulate.
Ten (10) members held this majority view. O'Brien explained that 0.4 mg/m3 measured
as thoracic particulate is a better surrogate. Members cited studies on diminished lung
function and the NIOSH Criteria Document. Members urged that the value be based on
an OSHA Risk Assessment. Mirer, Teitelbaum, Day, Newman and Wegman noted that
a PEL of 0.5 mg/m3 "total" particulate will not completely protect health. Wegman
emphasized that a PEL will not protect the skin.
The minority viewed the value as either between 0.5 and 1.0 mg/m3, or 1.0
mg/m3. Three (3) members, White, Howell, and Lick, held this minority view. They also
urged that the value be based on an OSHA Risk Assessment. Howell and White
recommended a voluntary application of these values. Howell stressed the importance
of fluid management and noted that a PEL of 0.5 mg/m3 alone cannot protect against
vapor or biological entities.
Two members, Cox, and Burch, did not have an opinion on what value should be
proposed.
In discussion, four members, Cox, Howell, O'Brien, and Sheehan, noted that a
higher PEL could be listed for straight fluids. Sheehan and Howell based their opinion
on the health data, while O'Brien and Cox recognized the feasibility issues. Lick noted
that a dual standard would be difficult to address in plants with multiple fluid types.
Action Level
The majority stated there should be an action level. Twelve (12) members held
this majority opinion. The rationale for an action limit includes concerns about the
variability of exposure levels in industrial processes and of sampling techniques. A
random sample as high as one half the PEL predicts that exposures greater than the
PEL will occur. Triggers are needed for sampling as well as other actions such as
medical surveillance in order to protect workers.
The minority opinion was that there should not be an action level. One (1) member,
Howell, held this view. Sampling and analytical problems at lower than the PEL were
cited. Voluntary approaches were emphasized.
Two members, Burch, and Cox had no comment on an action level.
Recommended Action Level
The majority viewed that 0.25 mg/m3 should be used as the action level. Eight
(8) members held this view. This opinion was based on the traditional statistical
approach of using half the PEL value. Mirer noted an earlier vote on best practice for
exposure assessment listing the action level as half the PEL. Mirer explained that an
action level detects and prevents over-exposure. Sheehan was concerned about
whether the sampling and analytical method could address values in this range.
A minority viewed that the committee should not "tie OSHA's hands" by providing
a specific action level. Three (3) members, O'Brien, Wegman, and Teitelbaum, held
this opinion. O'Brien, Teitelbaum and Wegman were concerned about residual risk at
0.25 mg/m3 and Wegman asked that OSHA figure out better ways of addressing this
issue.
Howell had another minority view and thought the number should reflect the limits
of the sampling and analytical method.
Lick expressed a different minority opinion, noting that the action level should be 0.5
mg/m3, since the action level becomes a de facto PEL. Lick also noted the concerns about
the sampling and analytical method and that without other components, a PEL and/or
action level would fail.
There was some general consensus that OSHA should identify alternate
triggers for action instead of an action level.
Burch and Cox did not comment on the value proposed for an action
level.
Short Term Exposure Limit (STEL)
The majority viewed that there was inadequate evidence to support a STEL.
Twelve (12) members held this majority opinion. Members were concerned about short
term high exposures. They noted anecdotal evidence of complaints of respiratory
irritation for short term high exposures. The concept of real time monitoring to
determine short term exposures was supported by members to provide information on
these conditions. Burch noted that short run operations with a lot of opening and
closing of doors produce peak exposures while continuous operations would have less
of a problem with peak exposures.
Three members, Teitelbaum, Day, and McGee had no opinion or comment.
Is more than a PEL necessary?
All 15 members noted the importance of including more than an exposure limit in
any OSHA action concerning MWFs. Howell explained that the combination of systems
management and medical surveillance would accomplish more than a PEL. White,
Cox, Howell and Burch noted that a regulatory approach should not be used.
All 15 members clearly stated that systems management is essential. White
noted that a PEL would go a long way to improve current conditions, but systems
management was needed to protect against problems such as dermatitis. Burch noted
that endotoxin could not be addressed with a PEL, but systems management would
reduce this problem. Mirer explained that design criteria for equipment, process control
to reduce misting, and fluid management should be the three major components of
systems management and also urged the inclusion of general ventilation. White, Cox,
Howell and Burch noted that a regulatory approach should not be used.
There was some debate, but no consensus, about whether the specifics of
systems management should be laid out by OSHA. O'Brien urged complete flexibility
while Sheehan urged defined, quantitative criteria. Newman suggested defined criteria
with some flexibility built in for emerging technological improvements. The committee's
view of best practice for systems management can be found at the end of Chapter Six.
The majority stated that medical surveillance was needed. Eleven (11)
members held this majority opinion. White, Newman and Mirer noted that medical
surveillance would capture problems not addressed by a PEL and systems
management. Mirer recommended active medical surveillance and noted that there will
still be problems of under-reporting of health problems. A detailed rationale for medical
surveillance and the committee's recommendation for best practice for medical
surveillance can be found at the end of Chapter Eight of this report.
The minority was not against all medical surveillance, but did not support the
best practices version of a medical surveillance program as found in Chapter Eight of
this report. Four (4) members, Cox, Howell, Burch, and White held this view. Cox
urged a common sense approach to medical surveillance especially for small business.
Howell, Burch, Cox and White cautioned against using medical surveillance as part of a
regulation. The ORC version of a voluntary medical monitoring program was put forth
as an alternative by some of those in the minority.
The Action OSHA Should Take.
All 15 members agreed that OSHA should act to address the issue of
MWFs.
The majority voted that an OSHA standard for MWFs is needed. Eleven (11)
members held this majority opinion. Anderson, O'Brien, Sheehan, and Wegman stated
that the standard should include a PEL, systems management and medical
surveillance. O'Brien viewed that the specifics of the systems management should be
in a non-mandatory appendix. Mirer explained that the most critical parts of a standard
are the PEL and exposure monitoring portions.
Members provided some rationale for choosing a standard. Mirer noted the wide
range of epidemiological studies. Mirer stated that a standard is needed for exposure
reduction, medical surveillance and the commitment to spend the money needed to
accomplish these objectives.
McGee noted that a standard would promote compliance by employers and
employees. Day cited his own experience noting that employers only pay attention to
standards. Teitelbaum urged OSHA to provide a special emphasis program and cited
inadequate MSDSs for MWFs. Lick opined that in time, a guideline might work, but at
this time, only a standard would accomplish what is needed in industry.
The minority voted that OSHA should publish guidelines for MWFs instead of a
standard. Four (4) members, Burch, Cox, Howell, and White held this minority opinion.
Howell and White noted the complexity of promulgating a standard on MWFs. Burch
explained that OSHA would have to prove a clear cut risk for a standard. White opined
that although the whole compilation of health effects is compelling, only a few studies
can be used in risk assessment. Howell and White explained that a guideline could be
implemented much quicker than a standard. White noted that industry has shown in
the ORC document that it is willing to act. Howell urged adoption of a non-regulatory
approach for users and product stewardship by suppliers. The cost burden of a
standard concerned White. Burch urged sensible action, acknowledging that good
employers will follow a guideline, while the bad ones will play the odds of an OSHA
inspection. Howell and White urged partnerships and cooperative efforts, and Cox
provided examples of such in his organization. Burch noted that over time, purchases
of new machine tools will result in lower exposures.
The issue of interim guidelines was discussed but not resolved by a vote.
Howell, Day and Sheehan thought interim guidelines until a standard is promulgated
would be a good idea. Sheehan opined that the committee could release its report as
guidelines if OSHA does not act in a timely manner. White suggested guidelines with
the threat of a standard if guidelines did not work, and gave examples of guidelines that
work.
Teitelbaum and Mirer strongly disagreed with interim guidelines. Mirer
explained that OSHA resources needed for standard promulgation would be used to
develop the guideline. Mirer urged the committee to disregard the time it takes to
develop a standard. Lick explained that OSHA could contract someone to develop a
guideline.
Systems Management
As noted earlier in this summary, the committee unanimously supports the use of
systems management of MWFs. Details about this issue can be found in Chapters
Three and Six of this report. At the end of Chapter Six is the committee's
recommendation for best practice systems management.
Exposure Assessment
The committee reviewed many different studies and heard testimony regarding
the different sampling and analytical techniques that can be used for MWFs. There are
advantages and disadvantages associated with each method. The committee accepted
the best practice exposure assessment program provided in Chapter Seven of this
report. This assessment program provides different sampling and analytical options to
the employer and allows for professional industrial hygiene judgement. In addition, a
qualitative assessment tool is provided at the end of Chapter Seven. The purpose of
this tool is to provide additional guidance for good industrial hygiene judgement and
good business management. The qualitative assessment tool allows employers,
especially small businesses, who are reasonably expected not to have excessive
exposures to avoid unnecessary air sampling. This approach is believed to be a
reasonable way of enhancing the technological and economic feasibility of the actions
recommended in this report while continuing to protect the workers who are exposed to
MWFs.
Medical Surveillance
Medical surveillance has been discussed in previous sections of this summary
and is recommended by the committee. A detailed rationale for medical surveillance
and the committee's recommendations for best practice are found in Chapter Eight of
this report.
Training
As noted in this summary, the committee wholeheartedly supports training and
outreach. The majority views that this should be part of a standard, while the minority
views this should be part of a voluntary action. Details of how this can be
accomplished in either context are found at the end of Chapter Nine.
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