Input received through Web Forum for identifying hazardous chemicals
for which OSHA should develop exposure reduction strategies.

Note: Comments that were inappropriate or completely off topic have not been included.

It is recommended that all chemicals included in the 1/19/1989 OSHA revision of PEL values be included in this effort. As stated by OSHA, and quoted below these values were and still are justified. Worker safety is still a concern when working with the current outdated values for these chemicals. OSHA must be better prepared to implement new PEL values knowing that they will likely be challenged in the court system as were the 1989 values.

"OSHA is amending its existing Air Contaminants standard, [1910.1000] including Tables Z-1, Z-2, and Z3. This amendment is limited to making more protective 212 Permissible Exposure Limits (PEL) listed in these Tables; setting new PEL's for 164 substances not currently regulated by OSHA; and maintaining other PELs unchanged. Changes include revision of the PEL; inclusion of Short Term Exposure Limits (STEL) to complement 8 hour time weighted average (TWA) limits; establishment of skin designation; and addition of ceiling limits as appropriate. All of the revised PELs are included in a single new Table Z-1-A which also includes the existing OSHA PELs under the Transitional Limits Columns. This rule effective 3/1/89; start-up date with any combination of controls is 9/1/89; start-up date for compliance with preference for feasible engineering controls is 12/31/92 or in certain circumstances

1) Strontium chromates

2) Polyisocyanate aerosol

Styrene is a chemical that has a much lower limit (TLV) of 20 ppm set by ACGIH compared to OSHA's PEL of 100 ppm on an eight hour time weighted average. Considering it is a Group 2B Carcinogen I think the levels should at least match the TLVs.

Hexavalent Chromium should be eliminated from use anywhere. It is used widely at Boeing in various processes and products. People take this home to their sick family members and they, with their reduced immune system get exposure.

Acetone- current PEL 1000ppm, NIOSH REL 250PPM

Widespread use and we know 1000ppm is too high.

H2S needs review. The current OSHA PEL is 10ppm however in January ACGIH published a recommended 1ppm PEL level.

MEK - Not sure of the PELs

My suggestion is that you review the most commonly used dangerous constituent chemical items first. Start with the solvents/chemicals that are used most broadly in manufacturing processes--these substances affect the greatest number of workers and consumers. I am amazed at the number of common chemicals used in paints, solvents, and polymers which "have no studies to date? or the information space provided on the MSDS = Unknown. Additionally, I feel that the overall usefulness of Material Safety Data Sheets has diminished over recent decades. Many MSDS are now virtually useless due to many that contain flagrantly errant, deceptive, or obfuscating statements. I do hope that the Globalized Harmonization will address some of my concerns here. By example, take a look at the industrial solvent company ZEP, specifically; a look at their Product: ZEP Powersolv 5000. My concern starts with Labeling,

MSDS and HMIS indicating this product in Non-Flammable yet small detailed text warns that vapors may accumulate to form ignitable concentrations at above 4.6% . Upon examination of each of the tree major components of this product, I find that each chemical?s MSDS is individually rated as NFPA Flammability of #3. ZEP has utilized carbon dioxide as their propellant, and so have declared this product as Non-Flammable--- this is wrong, and potentially very dangerous misinformation. Thank you for this opportunity to voice my concerns.

All pyrethroids

I would very much like you to consider Camp Lejeune's contaminants of concern in your quest for the Top Chemicals of concern. The list, compiled by Dr. Gerald LaBlanc, (NCSU), is provided below. As I research each of these chemicals myself, I will be sure to forward any pertinent information to you via this web-form. Thank you for this opportunity to participate in such an important process. ********

bis(2-chloroethyl) ether;
vinyl chloride;
methyl tert-butyl ether phenol;
di-N-octyl phthalate;
di-N-butyl phthalate;
methylene chloride;

It's difficult to put a meaningful comment into this comment box.

Some major chemical exposures known to pose a clear and present danger to health at prevailing levels pose major risk assessment and feasibility projects. Examples would include diesel exhaust particulate and fine particles generally.

A subset of substances are those for which there are authoritative recommendations for exposure limits substantially below current OSHA PEL's. Two agents below, benzene and formaldehyde, are regulated by 6(b) standards, but additional data and analysis have been recognized since promulgation.

Of those exposures for which the TLV, CalOSHA PEL or NIOSH REL is materially less than the OSHA Permissible Exposure Limit (PEL), or for which there is an limit and no PEL, about 40 are likely to impact occupational exposures, either because these limits may be exceeded, because the generic excursion factor may be exceeded for less than full shift exposures, or because the alternate limit may bring a measured exposure within reach of the Action Level concept. The authoritative limits cited may not be protective to the level consistent with Section 6(b) of the OSHA Act.

Asphalt (Bitumen) fume;
Butanol n-;
Butoxyethanol 2- (butyl cellosolve) [NIOSH REL 5 ppm];
Carbon black;
Carbon monoxide;
Cobalt - Elemental / Metal; Dichloroethane 1,2;
Diesel fuel No. 2 - Vapor & aerosol;
Ethoxyethanol [EGEE] 2- (ethyl cellosolve);
Flour Dust;
Formaldehyde [NIOSH REL 0.16 ppm];
Grain Dust;
Hexane diamine, 1-6;
Hexamethylene diisocyanate [HDI] 1,6;
Hexane n-;
Hexanone n-;
Hydrogen sulfide;
Iron Oxide;
Methoxyethanol 2- (methyl cellosolve);
Metalworking Fluids [NIOSH REL 0.5 mg/M3];
Nickel - Soluble inorganic compounds (as Ni);
Particulates Not Otherwise classified (total) (respirable fraction);
Styrene monomer;
Tetrachloroethylene [Perchloroethylene];
Toluene-2,4-diisocyanate [2,4-TDI];
Trimellitic anhydride;
Silica (Crystalline);
Sulfur Dioxide;
Sulfuric acid;
Wood Dust Red Cedar;
Zinc Oxide

I am working on a paper titled "OIMS/PSM application in the Alumina Industry". Eventhough the Alumina industry falls under MSHA, I strongly believe as operator and designer of this type of facilities that OSHA PSM should be used.

Caustic (Sodium Aluminate) in concentrations up to 350 g/l Na2CO3 and temperature up to 215 F. Large volume of this chemical particularly in the crystallization area where potential exposure for workers is high. (i.e. vapors, mist).

Hydrochloric and sulfuric acids in concentrations up to 10%.

These chemicals are well known for severe burns and causing blindness.

Mainstream cigarette smoke contains more than 41 OSHA regulated chemicals, including benzene, toluene, acrylonitrile, nicotine, and carbon monoxide. Exposures to these chemicals exceed PEL's. Cigarettes kill an estimated 147,000 workers each year. Ban smoking in the workplace and save some lives.

Methyl bromide is one of the most dangerous ozone-depleting substances, as well as dangerous to human life, and should be eliminated entirely. In US, 42 million lbs. are used every year.

Azinphos-methyl,a highly dangerous neurotoxin, should also be banned entirely, as should asbestos in all forms and products.

I would like to nominate the following:

Manganese- hard to measure as a ceiling; more recent toxicology indicates potential neurological effects although the level at which these occur and the exact types of effects remain a matter of controversy -there is more consensus though that the existing PEL is inadequate. There is widespread exposure to manganese in the metal fabrication industry (welders, thermal cutters etc).

Carbon monoxide- the existing PEL does not consider the potential cardiovascular effects. There is widespread exposure due to the use of LP or gasoline powered material handling equipment inside manufacturing sites & warehouses

HDI (hexamethylene disocyanate and IPI isophorone isocyanate) and IPI-these two isocyanates are widely used in spray coatings and there is no existing PEL for either compound-they have similar health effects to MDI/TDI which already have PELs.

There are also not PELs for the polymeric forms of HDI, IPI and MDI and data suggests that while the polymers are less toxic than the monomers, they still can induce asthma and other respiratory symptoms.

Wood dust: It is currently treated as a PNOR which is inadequate for a compound that has significant biological activity. It should have a specific PEL since it does not meet the definition of PNORs (i.e. PNORs should be applied to particles that are biologically inert, insoluble or poorly soluble; wood dust does not meet the first criteria). There is widespread exposure to wood dust in the wood products industry (i.e. carpenters, cabinet makers, door makers, furniture makers etc.)

I suggest that OSHA focusses part of its efforts on prevalent exposure to occupational carcinogens, e.g. diesel engine exhaust particulate, respirable crystalline silica, polycyclic aromatic hydrocarbons, welding fume, used engine oils etc. These probably contribute a large part of the current occupational cancer burden in the USA.

I would like to nominate nanoparticulates of all kinds as a chemical of concern. It's well accepted that nano-sizes produce a different physiological reaction than the "normal" sized particles encountered. Nanoparticulates are being researched based on that very characteristic, and when staff at my facility ask for safety directions, I feel there is inadequate information regarding short- and long-term exposures, risks, probabilities, etc.

I think that OSHA needs to establish a PEL for Triglycidyl Isocyanurate, a component found in polyester powder paints. The ACGIH has a TLV of 0.05 mg/m3. Most of Europe has very strict regulations regarding exposure, both skin and inhalation, to this chemical.

Chemotherapy/Hazardous drugs have no standard and the general duty clause link is tenuous. These are carcinogenic, mutagenic, teratogenic, endocrine distruptors, hormones etc. The OSHA technical manual outlines guidance, but it is exactly that - guidance. (widespread use of the chemicals, cancer is listed as most common cause of death currently, as cancer cases go up, so will the use of these hazardous drugs and the potential for worker exposure.) Some stakeholders need to see mandatory standards, or interpretations, in lieu of NIOSH or OSHA guideline documents.

I think OSHA should definitely look at the existing PEL for polychlorinated biphenyls (PCBs). Presently, there is a big gap between the OSHA's PEL and NIOSH's REL on this particular chemical's limit. Please take a closer look at this. This chemical falls into an endocrine disruptor category and it along with Bisphenol-A has a very affinity for the estrogen receptor, causing hormonal problems in women. Dr. Wesley Gray at Southern University in Baton Rouge is an expert in this field. He studied under Dr. Jack Gorskey, at Wisconsin Univeristy. They were very close to solving breast cancer, by performing research on a Type II estrogen-receptor where endocrine disruptors would not be active when entering the female's body. I received a MS working under Dr. Gray.

1) Diesel exhaust: widespread exposure, a carcinogen, no PEL
2) Respirable particulate, including ultrafine particulate: widespread exposure, no PEL
3) Welding fume: widespread exposure, a carcinogen, no PEL
4) Asphalt fumes: widespread exposure, a carcinogen, no PEL
5) Mixed refined petroleum solvents: widespread exposure, serious health effects, outdated PELs for Stoddard Solvent (500 ppm) and Petroleum Distillates (500 ppm) permit massive exposures. No PEL for kerosene or many other fractions.

2-butoxyethanol; many cleaners, but also a major component of fracking fluids that may show up in the water table and come in contact with crews; removed from EPA list in 1994, not regulated by OSHA; would help close the halliburton loophole to publish components of said fluids

Methylene chloride (dichloromethane) has a PEL that is too high and should be lowered.

After taking many samples of caulking in Mass. and New York areas and finding high levels of PCB's (polyclorinatedbhyfenals). OSHA should take a hard look at this chemical, it's removal and disposal, most of which has gone to ordinary landfills.

With the increased use of polysilicons for solar panels and semi-conductors, I would recommend OSHA addressing exposures to Chlorosilanes, notably Trichlorosilane and Silicon Tetrachloride.

Isocyanates, including MDI, TDI, and HDI should have thier PELs re-examined. MDI and TDI PELs are outdated while HDI does not currently have a PEL. Workers may be exposed to multiple kinds of isocyanates. This warrants a method that measures total reactive isocyanate groups coupled with a lower overall standard as many other countries have already done.

The following primary chemicals in throughtout healthcare and with many HCW exposed on daily basis.

Glutaraldehyde; Waste Anesthetic Gases; nitrous oxide; Enflurane; Isoflurane; Sevoflurane; Desflurane; Halothane

Isocyanates (There are more than TDI and MDI)


TCP"s, benzene, carbons in airline, airport environs. Employees are unprotected.

Acetone, mercury, toluene. The existing PEL's for these agents are so anitquated and are in drastic need for revision.

Superior 16 Spaint Gun Cleanter Health Hazard is a 2 Used daily more then one time. Extremely dangerous. This should be classified at least a 3 or 4. It give employees the idea it is not that dangerous. Sometimes employees do not wear their proper PPE because a level 2 health hazard is not that bad they think and the PPE is bulky and hard to work with the chemical gloves. I have hung the MSDS where they work. This chemical scares me. California baned it because it causes birth defects. Carcinogens. Lets make these chemical companies responsible for what they sell and the dangers to human life.

I am chairman of the Toxicology Committee of the American College of Occupational and Environmental Medicine (ACOEM), the largest physician group who champion the health and safety of workers. We have sent letters to OSHA asking that the current, terribly outdated Lead standard be revised to reflect the current scientific knowledge about the adverse health effects of low levels of lead in adults. The current OSHA PEL is woefully indaequate for protecting workers.

Lead poisoning causes adverse health effects in humans in a dose-dependent fashion. Although these adverse health effects have been recognized since antiquity, more recent biochemical and physiologic studies have clearly demonstrated the direct correlation of whole blood lead levels (BLL) and the development of significant neurological, biochemical, renal, reproductive, and cardiovascular effects, among others. While some of these adverse effects are much more serious in infants and children (e.g., the developing nervous systems), it has become clear that adults are not resistant to adverse effects, and that the current Occupational Safety and Health Administration (OSHA) lead standard which allows continued exposure until BLL exceeds 50 or 60 mcg/dL is inadequate to protect the health of the American worker.

The U.S. Department of Health and Human Services (DHHS) recognizes that elevated BLL's in adults can damage the nervous, hematologic, reproductive, renal, cardiovascular, and gastrointestinal systems, and that the overwhelming majority of these cases are workplace-related. The geometric mean BLL of all adults in the United States is <3 g/dL, and therefore DHHS recommends that BLLs among all adults be reduced to <25 g/dL.

The current OSHA standard was adopted in the 1970s, based on now-outdated >40-year-old science, when the geometric mean BBL values in the United States were 12.8 mcg/dL, and the normal BLL was considered to be <25 mcg/dL. The removal of lead from gasoline, from paints, and from solder in food cans, as well as other public health measures, has greatly reduced the average blood levels now to a geometric mean of 1.45 mcg/dL. Recognition of the particular sensitivity of the developing brain to lead prompted the U.S. Centers for Disease Control and Prevention (CDC) in 1997 to change its childhood lead poisoning surveillance guidelines to consider a normal BLL to be < 9mcg/dL.1 More recently, published studies have demonstrated decrements in cognitive scores in populations of children when BLL averaged >5 mcg/dL, and in adults with BLL >10 mcg/dL.

Therefore, the American College of Occupational and Environmental Medicine (ACOEM) is urging all employers utilizing lead in the workplace, as well as physicians caring for the health of U.S. workers, to adopt the Recommendations for Medical Management of Adult Lead Exposure published by an expert panel in 2007. These provisions call for medical removal when BLL exceeds 20 mcg/dL on any two consecutive blood tests or any single value exceeding 30 mcg/dL. While the current OSHA standard applies only to those workers exposed at the OSHA action level of airborne lead dust ≥30 μg/m3 as an 8-hour time-weighted average, ACOEM believes that this standard should be applied to all lead-exposed workers who have the potential to be exposed by lead ingestion, even in the absence of documented elevations in air lead levels. In addition, ACOEM urges OSHA to update its lead standard in order to better protect American workers and to align itself with the overwhelming scientific evidence of adverse health effects in adults with BBL. In keeping with the scientific evidence, ACOEM recommends that OSHA lower the medical removal BLL as outlined above

Kosnett MJ, Wedeen RP, Rothenberg SJ, Hipkins KL, Materna BL, Schwartz BS, Hu H, Woolf A. Recommendations for medical management of adult lead exposure. Environ Health Perspect. 2007 Mar;115(3):463-71.

The OSHA Lead Standard is clearly outdated and the current PEL for lead is not adequately protective based on multiple scientific studies. This substance should be a priority for review.

The PEL for methylene chloride (dichloromethane) is inadequate and out of date.

Also, recent information about dermal exposure to isocyanates such as MDI require a reassessment of the PEL for this group of chemicals.

Isoflurane, desflurane, halothane have no PEL because these anesthetics were not invented when PELs were first established...but now they are the most widely used and healthcare staff are exposed

Glutaraldehyde has widespread use in healthcare and potential sensitizer.

OSHA either needs to develop an appropriate PEL and/or provide for medical surveillance via BeLpt or other biological indicator for the various uses of beryllium. The most recent NAS (independent study for Air Force) has determined no safe level of exposure, but says exposure should be control to ALARA with mandatory med surveillance. OSHA needs to address the industry controls needed for this agent.

I hope OSHA and NIOSH manage to simply ban specific dangerous substances, like asbestos, which has been banned in the European Community. Asbestos, for example, is very hard to handle correctly.

When I wrote Death On the Job in 1978, I pointed out that the number of commercially available chemical compounds had increased from 17,000 in 1958 to 47,000 in 1971, and went on to write, "Since there are only 500 TLVs [threshold limit values listed by the American Conference of Governmental Industrial Hygienists (ACGIH), which provided the basis for most PELs once OSHA was created] in the OSHA regulations for existing hazardous substances, thousands of known and suspected toxic chemicals lack exposure standards...." (p. 82).

I arrived as the number of 47,000 commercially available chemicals by perusing CHEM SOURCES, Directories Publishing Co., Flemington, NJ, 1975 edition, which billed itself as "the most complete chemical sources guide published on the organic and inorganic products of the U.S. chemical industry."

CHEM SOURCES--USA for 2009 (it comes out annually) listed over 100,000 chemicals for which registry numbers have been assigned, and over 200,000 chemicals altogether. There must be a better way to figure out which chemicals are hazardous and which are not, and banning those that are used for trivial reasons. Not an easy task, and very little progress has been made, sadly, since I wrote DEATH ON THE JOB in the mid 1970s.

If you can ban asbestos, as the European Community has done, that is already a start.

Personnally I think it probably is a waste of resources for OSHA to issue PELs if it is just a number. However, I will list the candidates that I think would be the most useful.. Its a waste of resources because the process is tedious, contentious and results in numbers that are extremely high risk to workers (for example 1/100 risk of cancer from benzene and 4.5/100 risk of cancer from hex chrome according to OSHA's own analysis). I think a generic standard requiring assessment, monitoring, and controls of all chemical hazards would be a better approach.

Here is my wish list for missing standards:

diesel exhaust (no standard);
asphalt fumes (no standard);
dioxin (no standard);
glyphosate - most commonly used pesticide (no standard);
waste anaesthetic gases (no standard)

Additionally, OSHA should nominate gypsum to be studied by the National Toxicology Program, since this is the most widely used building material and there is very little short or long term toxicity data on this chemical. Mt Sinai and the Plasterers union nominated gypsum under the Bush administration and NTP concluded that this warrants further testing, but made it a low priority.

I can supply much more

(1) Air contaminants with PELs from 1971:

Acetone; Barium Sulfate; Maleic Anhydride, Methyl Ethyl Ketone, Styrene; Hydrogen Sulfide; Carbon Monoxide; Ethyl Benzene; Toluene; Trichloroethylene; Titanium Dioxide;

(2) Air Contaminants with no PEL's

Alpha Methyl Styrene; tertiary dodecyl mercaptan (TDM); N-Butyl Acrylate; Mineral Oil

Chemicals pertaining to paints and varnishes coatining are hazardous and due attention in terms of listing of PEL in respect of each generally used in the manufacturing . do we have such list

I nominate an update on the lead standard. Currently, only workers with exposures to airborne lead at the OSHA action level of airborne lead dust ≥30 μg/m3 as an 8-hour time-weighted average, it is clear that this standard should be applied to all lead-exposed workers who have the potential to be exposed by lead ingestion, even in the absence of documented elevations in air lead levels, and that the lead standard should be revised to adopt the Recommendations for Medical Management of Adult Lead Exposure published by an expert panel in 2007. These provisions call for medical removal when BLL exceeds 20 mcg/dL on any two consecutive blood tests or any single value exceeding 30 mcg/dL. I urge OSHA to update its lead standard in order to better protect American workers and to align itself with the overwhelming scientific evidence of adverse health effects in adults with BLLs well below the OSHA limits, such as suggested in Cal/OSHA Table 8.3 In keeping with the scientific evidence, I recommend that OSHA lower the medical removal BLL as outlined above.


OSHA only has a ceiling value (5 mg/m3 as opposed to ACGIH TWA 0.2 mg/m3 and NIOSH REL TWA 1.0 mg/m3 and STEL 3 mg/m3)

Evidence of Parkinson's type syndrome

Millions of welders are exposed daily

Wedling fume one of the most common things sampled for by OSHA

OSHA should develop a specific PEL for refractory ceramic fiber (RCF). Currently OSHA has a recommended exposure limit for RCF as part of its stewardship program with the RCFC. RCF usage is widespread throughout industry as a replacement for asbestos. Through OSHA s PSP with the RCFC, OSHA has already acknowledged and recognized that RCF exposures must be controlled. It is time to formalize a PEL based on current science, toxicological studies and risk.

Manganese - OSHA PEL is out of date. ACGIH has reduced TLV several times since OSHA's inception. An estimated 500,000 workers who perform SMAW, GMAW, and FCAW welding are exposed to manganese, a common constituent of welding consumables. Irreversible neurotoxicity is a well established health effect associated with manganese exposure.

The manganese PEL is very outdated; look at the data from the ACGIH "Documentation of TLVs" and the difference between the OSHA PEL and the ACGIH TLV for manganese.

I would like to nominate inorganic mercury. I have some past inspection experience with a facility that recycles lighting fixtures and other mercury containing materials. Toxic effects of mercury exposure are well known, but our PEL (listed as a ceiling, but enforced as an 8 Hr TWA) of 0.100 mg/m3 is out of date, when compared to the ACGIH TLV of 0.25 mg/m3 and the NIOSH REL of 0.05 mg/m3. Furthermore, I think there should be requirements regarding medical surveillance. Thanks for your consideration.

With the expansion in use of Carbon Nanotubes, I thnk we need a definitive exposure limit.

Decabromodiphenylethane (DBDPE, CASRN 84852-53-9) is a brominated flame retardant used in plastic and textile applications ranging from consumer electronics to wire and cable to textiles. Trade names for DBDPE are Saytex 8010 (Albemarle) and Firemaster 2100 (Chemtura). As a replacement for the fully brominated polybrominated diphenyl ether (PBDE) conger, BDE 209, DBDPE has been used in applications similar to those of the deca-BDE technical mixture. DBDPE has a chemical structure and physical properties similar to that of BDE 209. DBDPE is one of the major brominated flame retardant (BFR) products currently used in China, the application rate of which has grown at a rate of 80% per year in recent years (Cai 2008). Since deca-BDE, the number two flame retardant in global volume sold, is being phased out in the United States and the EU, and DBDPE appears to be a major replacement for deca-BDE, there is rapidly increasing demand for DBDPE which had been predicted to result in increasing DBDPE contamination in the future (Luo et al. 2009).

Detection in Environment and Wildlife:

DBDPE has been detected in both environmental and biotic media. DBDPE has been detected in sewage sludge and sediment from Sweden (Kierkegaard et al. 2004), Spain (Eljarrat et al. 2005), the United States (North 2004), and Canada (McCrindle et al. 2004). More recently, a comprehensive assessment identified DBDPE in sewage sludge from 12 countries on 3 continents (Ricklund et al. 2008). DBDPE has also been found in the particulate phase of air samples (Venier and Hites 2008) and in tree bark (Qiu and Hites 2008) suggesting that long-range atmospheric transport and deposition may be an important vector of DBDPE into the environment. Also showing DBDPE s long-rang transport potential is a new study which detected this chemical at measurable concentrations in bird eggs in the remote Faroe Islands of the Norwegian Arctic (Sagerup et al. 2010). Current concentrations of DBDPE in eggs of herring gulls from the Great Lakes are similar to or higher than those of BDE-209 and appear to be increasing after a comparatively short period of usage (Gauthier et al. 2009), suggesting that DBDPE may be more persistent and/or bioaccumulative than deca-BDE. Similarly, Luo et al. 2009 found DBDPE in nearly all Chinese waterbird species sampled with concentrations up to 700 ppb detected in Chinese-pond herons, suggesting that DBDPE is more bioavailable for aquatic biota than BDE 209. This is in agreement with Law et al. 2006 who found that DBDPE was biomagnified in an aquatic food web with the trophic magnification factor being up to 9.2. High concentrations of DBDPE have also been reported in captive pandas (Hu et al. 2008) from China s Pearl River Delta, where many e-waste recycling facilities are located.

Human Exposure:

DBDPE has been detected at significant levels in domestic dust from Europe (Karlsson et al. 2007), Boston (Stapleton et al. 2008), the UK (Stuart et al. 2008), Japan (Takigami et al. 2009), and Thailand (Muenhor et al. 2010). A recent study found that DBDPE was present in all dust samples taken from an e-waste region in China and that the estimated daily intakes (EDIs) of average adult and toddler in this were substantially higher than other brominated flame retardants measured (Wang et al. 2010).


Toxicity of DBDPE has been suggested by the few studies that have been carried out to date. Nakari and Huhtala 2009 assessed DBDPE toxicity both in vivo and in vitro using the freshly separated fish hepatocyte assay and standardized water flea and zebrafish egg-larvae tests. The fish hepatocyte assay, produced a clear dose-response curve in the presence of DBDPE and showed that DBDPE is estrogenic. In vivo tests showed that DBDPE was acutely toxic to water fleas. Moreover, DBDPE reduced the hatching rates of exposed zebra-fish eggs and raised significantly the mortality of hatched larvae. The authors conclude that because there is limited information available on the effects of DBDPE on the aquatic environments, it is crucial to obtain more data on the effects and effective concentrations of DBDPE along with its occurrence in the environment. Such data would enable reliable assessments of the risks posed by this flame retardant. In a study by Hardy et al. 2002, with funding from Albemarle, DBDPE administered to rats for 90 days was associated with an increased size of the liver relative to body weight. A newer study funded by Albemarle (Hardy et al. 20102) concluded that there was no evidence of maternal toxicity, developmental toxicity, or teratogenicity in rats or rabbits treated with DBDPE at dosage levels up to 1,250 mg/kg per day. However, these are gross endpoints. They did not measure neurotoxicity in either the dams or the offspring and no immune endpoints or measures of the effects on the endocrine system were given. There was no assessment of specific pathways known to be affected by these chemicals for any system. This study could be considered a dose-ranging study for future, more relevant studies.

Cai YY. (2008); Handbook of Modern Technology of Flame Retardance, pp. 35-45
Eljarrat E, Labandeira A, Martinez A, Fabrellas B, Barcelo D. (2005); Organohalogen Compd. 67: 459-461
Gao F, Luo X, Yang Z, Wang X, Mai B. (2009); Environ Sci Technol. 43:6956-6962
Gauthier LT, Potter D, Hebert CE, Letcher RJ. (2009); Environ Sci Technol. 43:312-317
Hardy ML, Margitich D, Ackerman L, Smith RL. (2002); Int J Toxicol. 21:165-170
Hardy ML, Mercieca MD, Rodwell DE, Stedeford T. (2010); Birth Defects Res B Dev Reprod Toxicol. 89(2): 139-146
Hu GC, Luo XJ, Dai JY, Zhang XL, Wu H, Zhang CL, Guo W, Xu MQ, Mai BX, Wei FW. (2008); Environ Sci Technol. 42: 4704-4709
Karlsson M, Julander A, van Bavel B, Hardell L. (2007); Environ Int. 33: 62-69
Kierkegaard A, Bjorklund J, Friden U. (2004); Environ Sci Technol. 38: 3247 3253
Law K, Halldorson T, Danell R, Stern G, Gewurtz S, Alaee M, Marvin C, Whittle M, Tomy G. (2006);
Environ Toxicol Chem. 25: 2177 2186
Luo XJ, Zhang JL, Wu JP, Luo Y, Chen SJ, Mai BX, Yang ZY (2009); Environ Sci Technol. 43: 306-311
McCrindle R, Chittim B, Konstantinov A, Kolic T, McAlees A, MacPherson K, Reiner E, Potter D, Tashiro
C, Yeo B. (2004); Organohalogen Compd. 66: 3744-3750
Muenhor D, Harrad S, Ali N, Covaci A. (2010); Environ Int. 36(7): 690-698
Nakari T, Huhtala S. (2009); Environ Toxicol. 25: 333-338
North K D (2004); Environ. Sci. Technol. 38: 4484-4488
Qiu X, Hites RA. (2008); Environ Sci Technol. 42: 31 36
Ricklund N, Kierkegaard A, McLachlan MS. (2008); Chemosphere 73(11): 1799-1804
Sagerup K, Her Sagerup K, Herzke D, Harju M, Evenset A, Christensen GN, Routti H, Fuglei E, Aars J, Str m H, Gabrielsen GW. (2010); New brominated flame retardants in Arctic Biota.
Stapleton HM, Allen JG, Kelly SM, Konstantinov A, Klosterhaus S, Watkins D, McClean MD, Webster TF. (2008); Environ Sci Technol. 42: 6910-6916
Stuart H, Ibarra C, Abdallah MAE, Boon R, Neels H, Covaci A. (2008); Environ Int. 34(8):1170-1175
Takagami H, Suzuki G, Hirai Y, Ishikawa Y, Sunami M, Shn-ichi S. (2009); Environ
Int. 35(4): 688-693
Venier M, Hites RA. (2008); Environ. Sci. Technol. 42: 4745 4751

Wang J, Ma YJ, Chen SJ, Tian M, Luo XJ, Mai BX. (2010); Environ Int. 36:535-541

TMAH- Tetramethyl ammonium hydroxide has been linked to worker deaths from dermal exposure overseas at semiconductor manufacturers yet we have no guidance- PEL, TLV, or otherwise. Usage and concentration has been increasing in the electronics industry as a cleaning solution.

I believe that polyvinyl acetate (CAS #9003-20-7) warrants priority as a chemical of concern.

PVA exposure is very common in the workforce and in the public, being used as spray-in mold release agents, glues, plastics, cosmetics, and even as a primary ingredient in chewing gum, yet the Cosmetic Ingredient Review (CIR) Expert Panel concluded that the available data were not sufficient to support safety. PVA has been identified by the Environment Canada Domestic Substance List as as "expected to be toxic or harmful" and there is no established PEL for exposure to this chemical.

Carbon monoxide PEL should be lowered to 25 ppm.

ACGIH TLV is currently 25 ppm, The Cal OSHA standard is 35 ppm. The current PEL is not protective.

the list that follows is an approach, rather than a list of specific chemicals:

1. Toxic chemicals need to be classified and categorized for review by OSHA NOT a review of chemicals one at a time, as is done now.
2. Regulate chemicals for toxicity at any point along the chain of manufacture, use and disposal.
3. Need to focus on alternatives to dangerous chemicals.
4. OSHA must begin to hold employers accountable to abate violations immediately upon discovery, not wait until after closure, the latter of which can take years.
5. Holistic thinking tear down the wall between risks to workers and risks to community.
6. Focus on build-up of chemicals in the environment and impact thereof.
7. End of life (for a chemical) considerations - up front.
8. Development of safer products, chemical substitutions.
9. Re-examine who handles what, i.e., OSHA, EPA, Food and Drug Admin, Agriculture, etc. and how agencies work together to best accomplish the goals. One example of failure in this regard: the pathogenic sludge from feedlot cattle that ends up on soil and in rivers.
10. Meaningful fines, tort liability and criminal liability: Only when corporations are hit meaningfully in the pocketbook will meaningful change occur.

Sources for some of the above: Geiser, K, Tickner, J., Torrie, Y. Reforming State-level chemicals management policies in the US: Status, Challenges and Opportunities. New Solutions, Vol. 19, No. 1, 2009, and Monforton, Celeste for 4. above.

I believe silica is probably the most prevalant harmful exposuse in the work place today. Most companys see it as common dust and will never see the financial impact because most of the medical effects will come post retirement and end up in the laps of the taxpayers through medcare.

I commend OSHA for creating this outreach mechanism. Although this Web Forum is less cumbersome than a traditional docket, I hope there will be some thought given to making the comments of others visible to all, as they would be under the docket mechanism, perhaps with the identities of commenters redacted if that is deemed necessary. I also suggest you consider creating a way for stakeholders to upload or otherwise transmit file attachments to help document this record; in this comment, I will provide several URLs where relevant files could be found, but others cannot readily be found online.

I would like to suggest one particular chemical as a high-priority candidate for PEL development, but would like to devote the bulk of this comment to the much more important issue of how OSHA can in some systematic way identify all of the substances that deserve high priority (not just ones suggested idiosyncratically by commenters like me or by Agency staff), and how it can then sensibly triage among the list to find the truly most important PEL candidates for near-term action.

1. The one specific new substance I urge the Agency to consider for near-term PEL development is 1-bromopropane, a.k.a. n-propyl bromide or nPB. I know of no other substance that has simultaneously been the subject of so many recent positive bioassays, human epidemiological studies and case series in the medical literature, and yet is so aggressively being marketed as a green alternative to solvents such as methylene chloride and perchloroethylene. In 1999, OSHA nominated nPB (and its more toxic isomer 2-bromopropane, a contaminant of commercial nPB) for comprehensive testing by the National Toxicology Program (the 12-page nomination document can apparently only be accessed online by doing a Google search for OSHA nomination bromopropane , and then clicking on the topmost link suggested the URL itself does not work directly). The testing was finally completed several years ago, and nPB was positive for carcinogenicity in both mice and rats, at multiple tumor sites. I have computed an EPA-style cancer potency factor (upper confidence limit on the linear term of the LMS dose-response function) for nPB based on the mouse lung tumor response, and I estimate that a 45-year working lifetime (8 hr/day) exposure to 25 ppm (which is the current informal recommendation for occupational exposure from EPA; the TLV, by the way, is 10 ppm) would pose an excess cancer risk of slightly more than 1 chance in 100 which of course is grossly intolerable; it is ten times the highest risk that could possibly be deemed insignificant under the Benzene decision.

One useful and very recent summary of the medical and toxicological literature on nPB can be found in a report I wrote for the city of Philadelphia, at Perc & nPB.pdf (this is a rather complicated URL; the navigation to it begins at But new reports are coming out monthly, so here is an even shorter and real-time summary of the problem: (1) a new study by Li et al. ( Dose-Dependent Neurologic Abmormalities in Workers Exposed to 1-Bromopropane, forthcoming in J Occ Env Med) claims that a human LOAEL for neurotoxicity is approximately 1.5 ppm for two years; (2) a new study by Blando et al. ( Preliminary Study of Propyl Bromide Exposure among New Jersey Dry Cleaners as a Result of a Pending Ban on Pechloroethylene, forthcoming in J Air and Waste Mgmt Assoc) shows that breathing zone TWAs among various dry cleaners using nPB averaged over 40 ppm; and (3) it is well known that dry cleaning is less emissive an operation than adhesive use, metal cleaning, and other touted applications of nPB. So **prevailing worker exposures** to nPB may be upwards of 20 times higher than a human low-effect level (!), and correspond to cancer risks that may exceed 1 in 100. This is a current worker-health problem that is only getting worse with time; I urge OSHA to make nPB a very high priority for a PEL.

2. Very briefly, let me summarize a few of the different (perhaps complementary) ways OSHA could expand the list in a more systematic way.

(a) OSHA should certainly review the record we developed in the former Directorate of Health Standards Programs circa 1996 (see 61 Federal Register, January 24, 1996, pp. 1947-1950). The HSP staff and I had lengthy internal discussions, reached out to stakeholders informally, and held a public meeting on 2/24/96; we determined that the following 20 substances were of highest priority, based on careful thought about exposures, potencies, and stakeholder interest:

Carbon disulfide;
Carbon monoxide;
Dimethyl sulfate;
Ethylene dichloride;
Hydrogen sulfide;
Manganese & compounds;
Mercury & compounds;
Nitrogen dioxide;
Sulfur dioxide;
Toluene diisocyanate;
Trimellitic anhydride;
Vinyl bromide;

I believe Lyn Penniman or Bill Perry would be the most knowledgeable DSAG staff about this phase of OSHA s PEL work, and might still have a copy of the transcript of the public meeting. Most importantly, we performed substantial quantitative risk assessment (QRA) work on six to eight of the above substances between 1996 and 1999 (certainly including CS2, glutaraldehyde, Mn, hydrazine, and trimellitic anhydride), but ran up against the perennial problem of the economic analyses being years behind the scientific analyses; none of the former were completed before the Clinton Administration ended. I think this is a general lesson for the future of the PELs: OSHA should increase the resources and general level of expertise of the economic analysis staff, but should also (regrettably) tend to choose PEL substances that combine the required elements of widespread exposures and/or high potency, but that also tend to be easier to analyze the economics of. For example, a substance like perchloroethylene might fit the bill, as it is very widely used, but might only have to be supported by an economic-feasibility determination in one major application (dry cleaning) and perhaps 1-2 minor ones. This nod to reality is unfortunate, as substances that are ubiquitous and hard to analyze economically (permeate many industry sectors) are probably more important to regulate, other things being equal, but due to the relatively poor performance of the economic-analysis function at OSHA, other things are not equal. Nevertheless, intolerable risks should be considered for reduction even if they affect very few workers ironically, one of the excuses for dropping the 1996 PEL update project several years later was that the 6-8 substances with risk assessments together were not important enough ironic because dropping it was championed by the OSHA manager who had previously convinced HSP to cull from the list several more important substances because the economic analyses of them was too involved.

(b) OSHA should also look at , which documents California s work on identifying risky substances that lack modern PELs, and contains some excellent work showing the feasibility of setting dozens of science-based OELs relatively quickly.

3. To set priorities among whatever list you develop, I strongly suggest you use methods of quantitative risk assessment. A more rudimentary but still very useful approach would be to rank-order PEL candidates by the highest ratio of a quantity such as (PEL/TLV) or (PEL/RfC) (for non-carcinogens) or (PEL/URF) (EPA unit risk factors for carcinogens). In testimony I presented at the March 5, 2010 OSHA rulemaking hearing on updating the Hazard Communication Standard, I submitted several results of my analysis of approximately 750 substances that have PELs, TLVs, and/or either RfCs or URFs. I showed that the TLV/RfC ratios have lower variance than the PEL/RfC ratios, reflecting the obvious fact that the PELs are either archaic TLVs (developed when the science was less well-developed) or in a few cases set by subsequent 6(b)(5) rulemaking and therefore set with reference to economic feasibility and not (despite widespread misunderstanding) by risk. My testimony and Powerpoint is in Docket OSHA-H022K-2006; I would be happy to share with OSHA my raw spreadsheet containing all the substances, reference values, and computations, upon request.

4. The approach I suggested above, while in my opinion far better than impressionistic priority-setting, does ignore exposure, which ought to be considered along with potency to prioritize via the gold standard of risk. As you know, I have received through litigation (Finkel v. US Dept. of Labor, 2007 U.S. Dist. LEXIS 47307 (D.N.J. June 29, 2007)) a complete copy of the Salt Lake City database containing 2.6 million OSHA air and other sampling results from 1979-2009. Although problems (not of a technical nature) have recently put a temporary hold on funded work I have been undertaking to analyze the temporal, spatial, and firm-level patterns in the database (and analyses of OSHA s past and present response to patterns of worker overexposures), one of my planned tasks is to generate statistical distributions of prevailing exposures for substances whose exposures likely exceed frank-effect or intolerable-risk levels. The "worst" substances, of course, are those where the actual exposures, not just the allowable exposures, are the highest with reference to science-based levels of health concern. As the PEL prioritization work continues at OSHA over the coming months, I would be pleased to share any results I obtain from this task, and perhaps to discuss accelerating this phase of the work at my end if that would be of assistance.

Thank you for the opportunity to comment on these fundamentally important public health issues.

I would like to see some work related to NIOSH recommendations for anesthetic gases (to inlcude more currently popular gases such as isoflurane). There is also too little attention focused on reproductive hazardous (with isolated exceptions) and I would like to see this addressed as a general category (as a general class of regulated chemicals) initially and then add to those specific compounds (limits) as data is made available via appendix. This type of oversight might introduce a banding concept as opposed to regular PELs.

Silica - widely found and frequent worker exposure with potentially serious health effects including death.

Carbon monoxide - same reason.

Both have NIOSH and ACGIH limits much lower than current OSHA PELs. OSHA has no Ceiling limit for CO which has acute effects.

Please address the on-going risk to healthcare workers exposed to hazardous anti-cancer drugs. Those listed below are a good place to start.

TABLE 1 Antineoplastic Agents That are Classified as Known (Group 1 )or Probable (Group 2A) Human Carcinogens_______________________________________Group 1

Arsenic trioxide;
Azathioprine BCNU;
Chlorambucil CCNU;
Chlornaphazine Chlorozotocin;
Cyclophosphamide Cisplatin;
Etoposide Teniposide;
Myleran Doxorubicin HCl;
Melphalan N-Ethyl-N-nitrosourea;
Tamoxifen MelclorethamineHCl;
Thiotepa N-Methyl-nitrosourea;
Treosulfan Procarbazine HCl;
Mustargen-Oncovin-Procarbazine-Prednisone (MOPP);
Adapted from the International Agency for Research on Cancer.9

I would be happy to provide additional information.

Thank you

Trichloramines form in many environments where chlorine is used to provide safe water. There is no PEL, no TLV and thousands of workers are exposed.

Need more awareness on the hazard of Nitrogen and other inert gases especially in oil refinerys where the hazards are present but not always posted.

We need a standard for bromopropane which we are seeing more of as an "environentally -friendly" degreaser. Also, we need a std for nitrous oxide which is still in use in some dental practices. A std is needed for waste anesthetic gases (enflurane, etc.) since they are all very toxic. In addition, any corrosive chemical should have a ceiling limit, not just a PEL, such as for HF, nitric acid.

I have two chemicals which I believe should be addressed.

The first is diacetyl. Currrently, there is no PEL established for this chemical. However, the agency thought there are so many issue surrounding the use of this chemical, a National Emphasis Program was developed in response to employee exposure and the development of bronchiolitis obliterans, which is a non-reversible and fatal disease by workers exposed to diacetyl.

The second is silica. I realize there is already a PEL for silica, but I believe it is inadequate, particularly in construction. I do not believe that a worker can be exposed to 10x as much silica in construction, without suffering long term health effects. One of the greatest workplace industrial disasters in American history is the Hawk's Nest incident. The link between silica exposure and silicosis is clearly defined. I believe that not only that the

PEL for silica be revisited, but that silica deserves it own expanded health standard, like asbestos, lead or chromium.

Thank you.

It would be nice to have a silica standard.

There are large numbers of chemicals that produce a common end point in their action as toxicants, namely excessive NMDA activity. These include large number of organic solvents and related compounds, three classes of pesticides, organophosphorus/carbamate, organochlorine and pyrethroid pesticides, hydrogen sulfide, carbon monoxide and mercury (and probably organic mercurials). The toxicant action of each of these classes of chemicals has been shown to be substantially reduce by using an NMDA antagonist and known pathways of action lead from each of these to produce excessive NMDA stimulation. There are still other toxicants showing similar patterns of action, including several herbicides and one commonly used class of fungicide. Many of these toxicants can act synergistically with each other. I think by asking about individual chemicals, you are missing the forest for the trees. I would like to email you a paper documenting much of this, but am unsure how to do so.

Here is my list of the chemicals of immediate concern

1- Chlorine
2- Ammonia
3- Phosgene
4- Benzene
5- Formaldehyde
6- Hydrogen Cynide
7- Gasoline
8- HydroChloric acid
9- Hydrogen Flouride
10- Ethanol

I work organizing household workers and something we talk about is bleach and ammonia and the dangers of mixing them together, which a surprising number of people do not realize. I don't think this is said on either bottle.

the PEL for lead is much to high, every one thinks it needs to be cut in half

thank you

I would like to nominate n-propyl bromide (also known as 1-bromopropane, and hereinafter as nPB ) (CAS No. 106-94-5) for immediate establishment of a permissible exposure limit ("PEL"). I describe briefly below the uses of and widespread worker exposure to nPB. Thereafter, I briefly discuss case reports, scientific studies, and other information that demonstrate that workplace exposure to nPB poses a significant risk of material health impairment, and provide lowest-observed-effect levels for several serious endpoints which could serve as bases for a PEL.


NPB is a brominated hydrocarbon with a strong odor. Its chemical formula is C3H7Br. NPB is used as a carrier solvent in aerosols and adhesives. Some brand names of products using nPB are: Abzol, EnSolv, and Solvon cleaners; Pow-R-Wash NR Contact Cleaner, Superkleen Flux Remover 2311, and LPS NoFlash NU Electro Contact

Cleaner aerosols; and Whisper Spray and Fire Retardant Soft Seam 6460 adhesives.

It also is used to remove wax, oil, and grease from electronics, metal, and other materials. Specific applications (see 72 Fed. Reg. 30168, 30171 (May 30, 2007)) include:

Aerosol Solvents. NPB is used as an aerosol solvent in lubricants, coatings, or cleaning fluids for electrical or electronic equipment; lubricants, coatings, or cleaning fluids for aircraft maintenance; and spinnerrette lubricants and cleaning sprays used in the production of synthetic fibers.

Adhesives. NPB is used in adhesives for laminates, flexible foam, hardwood floors, tire patches, and metal to rubber adhesives. Of these applications, nPB-based adhesives have been used most widely in spray adhesives used in manufacture of foam cushions, and to a lesser degree in laminate adhesives.

Electronics, Metal, and Precision

Cleaning. NPB is used in open vapor degreasing applications to remove processing lubricants such as oils, greases, and waxes which have been applied to aid manufacture but need to be removed before further processing of the manufactured substance.

As a result of the growing emissive use, global production of nPB was estimated to be 20,000-30,000 metric tonnes in 2007. It is assumed to be produced in China, France, India, Israel, Japan, Jordan, and the United States. China is estimated to have produced around 20,000 metric tonnes in 2008, of which approximately 40% were exported. Use as a solvent was reported to be growing at a rate of 15-20% per year in the United States (5,000 metric tonnes) and Asian countries other than China. Solvent use in Japan was 1,100 - 1,200 metric tonnes in 2009. No information was available to the United Nations Environment Programme ("UNEP") for other regions. (Montreal Protocol On Substances that Deplete the Ozone Layer, Report of the UNEP Technology and Economic Assessment Panel (Progress Report, Volume 2, May 2010), 59.


Workplace exposure data for nPB were collected by the Environmental Protection Agency ("EPA") Significant New Alternatives Policy ("SNAP") program from a variety of sources. Given its use across a variety of applications, some of which are uncontrolled, it is not surprising that there is a wide range of exposures in the workplace, from a few parts per million ( ppm ) up to 150 ppm or more. The data, both raw and in summary form, are available in the EPA SNAP docket (EPA-HQ-OAR-2002-0064-0015). A recently published study of exposure to nPB in New Jersey dry cleaning shops, found exposures as high as 54 ppm (Blando, et al., Preliminary Study of

Propyl Exposure among New Jersey Dry Cleaners as a Result of a Pending Ban on Perchloroethylene, J. Air & Waste Manage. Assoc. 60: __-__ (2010)).

Health Effects

Reproductive Toxicity. In a proposed rule to list nPB as acceptable for certain applications and unacceptable for others under its SNAP program, EPA discussed the available reproductive toxicity data in some detail (72 Fed. Reg. 30168 (May 30, 2007)). EPA based its analysis of occupational exposures on effects on sperm motility observed in a two-generation reproductive toxicity study employing a benchmark dose ("BMD") calculation. Since that time, additional BMD calculations have been developed based on effects on estrus cycle in the same multigeneration study. Taking these into consideration, it is possible to develop a reference concentration ("RfC") of 0.17 ppm for male and female reproductive effects.


There have been a number of reports of severe neurotoxicity in workers exposed to nPB. The effects noted relate to lower limb peripheral nerve effects with adverse sensory responses. These effects are qualitatively similar to those seen in earlier rat experiments -- limb weakness progressing in some cases to paralysis. Central nervous system effects also were reported in a proportion of human cases. The consistency of severe effects across multiple independent investigations is remarkable and, although the measurements of atmospheric levels have limitations, the exposure levels associated with effects is surprisingly low. Many of the case subjects needed hospitalization and the reversibility of the effects is still in question. A publication by Majersik et al. provides a complete clinical analysis of the effects and indications of the slow recovery, if any, observed in patient follow-up (Majersik et al., Severe Neurotoxicity Associated with Exposure to the Solvent 1-Bromopropane (n-Propyl Bromide), Clinical Toxicology 45: 270-276 (2007)). More recently, two cases were reported involving workers exposed to nPB (in vapor degreasing and dry cleaning, respectively) who were diagnosed with clinical manifestations of nPB (Perrone et al., Neurologic Illness Associated with Occupational Exposure to the Solvent 1-Bromopropane New Jersey and Pennsylvania, 2007 2008, Morbidity and Mortality Weekly Report 57(48): 1300-1302 (2008)) . Neurotoxicity in workers exposed to nPB is of substantial concern. A recently published study showing neurophysiological effects in workers exposed to a range of levels allows for derivation of a dose-response relationship for female workers (Li et al., Dose-Dependent Neurologic Abnormalities in Workers Exposed to 1-Bromopropane, J. Occup. Environ.

Med 52: 769-777 (2010) ). This well-conducted study allowed the authors to calculate the lowest dose level at which female workers would be likely to experience measurable adverse effects (neurological and red blood cell reduction in number). This exposure is 1.28 ppm (presumably an 8 hour time-weighted average). Obviously, the PEL would need to be lower to address sensitive sub-populations and provide some margin of safety.


Perhaps the most significant recent information relevant to the health hazard of nPB is the report of two-year carcinogenesis bioassays recently conducted and reviewed by the National Toxicology Program ("NTP"). A draft report (NTP Technical Report 564 (Board Draft)), which was unanimously approved by the NTP Technical Reports Review Subcommittee, shows:

Clear evidence of carcinogenicity in female F344 rats (adenomas in large intestine and equivocal evidence for skin tumors)

Some evidence of carcinogenicity in male F344 rats (adenomas in large intestine, skin tumors, and equivocal findings for mesotheliomas and pancreatic adenomas)

Clear evidence of carcinogenicity in female B6C3F1 mice (lung tumors)

No evidence of carcinogenicity in male B6C3F1 mice.

At this time, there are no reasons to assume that the mode, or modes, of action by which tumors are induced by nPB are not relevant to man and thus a linear, no-threshold dose-response relationship should be assumed. Using standard methodology for the calculation of cancer potency and risk estimation (the linearized multistage model) applied to the incidence of mouse lung tumors yields a q1* term. This value is the 95% confidence limit of the linear term resulting from the model. The cancer potency term for mouse lung tumors from the NTP bioassay is a risk of 1.95 x 10-3 per ppm (lifetime exposure). This potency value indicates that a lifetime risk of 1 in 10,000 is potentially associated with an exposure of 0.05 ppm or 0.25 mg/m3.


NPB is being aggressively marketed as an unregulated alternative to chlorinated solvents in a variety of applications. Indeed, sales literature for nPB emphasizes that it is essentially unregulated. Sales of nPB in adhesive and solvent cleaning uses are already substantial and appear poised for further growth.

The results of the recently reported carcinogenicity bioassays show clear evidence of carcinogenic activity in female rats and female mice. An estimate of carcinogenic potency using standard methodology shows that the cancer potency is similar to or higher than that of the regulated materials nPB is being marketed to replace. Moreover, observations of toxic effects of nPB in animal experiments and workers exposed at various levels demonstrate that exposed worker populations may face other serious health risks, including reproductive effects (male and female), liver and kidney toxicity, immunotoxicity, and effects on red blood cells and hemoglobin. High levels of worker exposure have led to a number of documented cases of lower limb paralysis that has been slow to improve; the onset of adverse effects on peripheral nerves has been detectable in workers exposed at very low levels (estimated lowest-observed-effect level was 1.28 ppm).

It is hard to imagine that nPB would not rank near the top as a candidate for an enforceable workplace limit, under Section 6(b)(5) of the Occupational Safety & Health Act or whatever criteria are being applied.

Styrene- inadequate PEL for a suspected carcinogen

Titanium Dioxide- widespread use of a chemical that has recently been listed as a possible carcinogen

It would be good to require protections for farmworkers from methyl iodide and any other pesticides they might handle in the course of their work. These chemicals are often carcinogenic and they can increase the risks of birth defects, among many other problems.Workers should at least wear protective gear when handling such chemicals.

Also, much of the uranium in nuclear plants and uranium mining could be quite toxic and increase the risks of cancer. In high exposures, it can cause radiation sickness.

I wish to nominate a category of hazardous chemicals that have not been adequately studied and for which no PELs exist. That category is therapeutic drugs used to treat cancer, transplant rejection and other diseases but which have an inherent risk of causing cancers, reproductive risks or other adverse effects in health care workers. These drugs are in widespread use with an estimated exposure to more than 5.5 million health care workers. NIOSH identified the hazard and exposure potential in its 2004 Alert on exposure: Investigation into this issue has resulted in a series of adverse effects suffered by a representative number of workers. ( This issue continues to be studied but not addressed by OSHA except in limited recommendations. The diversity of the drugs makes determining PELs very difficult in that the average worker is exposed to numerous drugs within a work period. Many of the drugs used in therapy meet the definition of "hazardous" in the HCS. More needs to be done to delineate the extent of exposure and the limits to which health care workers should be exposed. Even if only the top 10 drugs used in therapy were studied for PELs it would be a boon to the workers exposed every day.

silica - Rationale 1) It is the most prevalent carcinogen to which employees are exposed, especially in the construction industry. No other carcinogen has more exposed employees than those regularly exposed to silica. 2) When employees are overexposed it is often at levels well above, such as ten or fifteen times, the PEL. 3) Because the workers who are exposed are often in the construction industry, they do not have an anchor employer who can conduct medical surveillance over time as they progress in their careers. Even the union construction workers are "on their own" with respect to proper medical surveillance as they migrate from one employer to another. 4) The PEL for silica is difficult to regulate properly because the area offices need to prove an overexposure in order to get the employer to do anything. Proof of an overexposure means air sampling. The transitory nature of construction exposures mean that area offices have to continually conduct air monitoring to show that their citations reflect a representative exposure level. The need to conduct air monitoring for every citation really hampers our enforcement. 5) Because OSHA has failed to properly regulate silica for so long, construction contractors seem to feel that implementation of respirator programs and engineering controls are somehow "optional".

Ontario currently updates their OEL s every year. The Ministry of Labour creates a proposal from the adopted changes from the ACGIH TLV s for the latest year and provides a comment period. If anyone raises any significant objections the proposal is put on hold.

I want to draw OSHA s attention to the 2009 submission to the Ministry of Labour from the Occupational Health Clinics for Ontario Workers Inc. (OHCOW)

OHCOW endorses the Ministry s 2009 proposals for lower OELs for beryllium, diethanolamine, ethanol, ethylenimine, Ferbam, methyl parathion, propylenimine, sulphur dioxide, sulprofos and vanadium. They also comment on the Ministry s failure to act on past proposals to lower OELs for silica, wood dust, and blood lead indices and provides a summary of the literature for each of these OHCOW makes recommendations for five additional OELs based on the clinics experience indicating that these substances often sicken Ontario workers. These are for OELs for ozone, manganese, particulates not otherwise classified, metalworking fluids, and diesel exhaust. OHCOW provides a summary of the literature for each of these OELs.

In addition, the OHCOW submission presents compelling arguments why the Ministry of Labour should not rely solely on OELs to protect workers from chemical exposures.

As a hospital-based industrial hygienist, I have long been frustrated by the lack of an OSHA PEL for modern halogenated waste anesthetic vapors (WAVs). NIOSH Publication No. 2007-151: Waste Anesthetic Gases - Occupational Hazards in Hospitals is out-of-date, as it has not been updated to reflect the newer halogenated inhalation anesthetic agents such as isoflurane (Forane) which is itself being replaced with sevoflurane and desflurane in human medicine. However, isoflurane is still in use in vetinary medicine, both in therapeutic and research animal surgery. Moreover, a number of important WAV studies of chronic adverse health effects have been published since 1977, and these studies should be consulted in setting a PEL for these agents. This is of great concern due to the large number of health care, vetinary and research workers who are exposed to these inhalation anesthesia agents on a regular or periodic basis, because the PEL should be protective of any potential chronic adverse health effects from low but potentially chronic occupational exposure. Also it is requested that OSHA consider the feasibility of developing a metabolic biological exposure index (BEI) for exposure to these WAVs. Thank you for your consideration.

Carbon Monoxide (PEL Inadequate) - I recently was hospitalized and treated for carbon monoxide poisoning. The theoretical exposure calculated by the Coburn equation was less than the 50 ppm TWA PEL from OSHA. I believe OSHA should take notice of California, Canada, and ACGIH and implement a level of AT LEAST 1/2 the current level (ie 25 ppm 8 hr TWA).

Nitrogen Dioxide (Inadequate PEL). This toxin can cause serious lung issues at levels far less than the current ceiling of 5 ppm. I have seen 2 cases of Work Related Asthma which may be attributed to the increased NO2 levels in the atmosphere in which I work. A level even less than the 1 ppm STEL that NIOSH recommends may be in line.

Whole Diesel Exhaust - (No PEL In Place) - There needs to be rules requiring ventilation and limits in place where workers are exposed to diesel exhaust indoors. It should be a requirement that workers are exposed to a minimal amount of whole diesel exhaust by engineering controls or other measures, and not rely on natural ventilation and other poor excuses to protect workers. It is generally accepted knowledge that whole diesel exhaust can cause cancer, therefore exposure should be kept to a minimum.

Peracetic acid (PAA) CH3CO3H, is widely used in health care, food processing and water treatment. In healthcare solutions are prepared and items to be disinfected are immersed in the solutions, in food processing PAA is sprayed on to meats as a germicide and used to sanitize food processing equipment. The widespread use and modes of use result in the potential widespread potential exposure of workers to PAA. PAA is a primary irritant and strong oxidant , stronger than hydrogen peroxide, which has an OSHA PEL of 1 ppm. The EPA has established an AEGL 3 (hrs) of 0.17 ppm. I recommend that OSHA develop a PEL for PAA, probably around 0.1 to 0.2 ppm (8 hr TWA).

Glutaraldehyde is still widely used in health care, though the use has declined in recent years. Glutaraldehyde solution is used to disinfect medical devices and so operators must prepare solutions, immerse and remove medical devices from the solution and so there is a large potential for worker exposure. Glutaraldehyde is an irritant to the eyes and respiratory system and is a known sensitizer.

o-phthalaldehyde (OPA) has gained widespread acceptance in healthcare as a a safe alternative to glutaraldehyde. OPA is However, as an aromatic dialdehyde, it is a primary irritant and a sensitizer. OPA has a lower vapor pressure and a lower odor and thus is not as noticeable to workers. OPA solutions are used to disinfect medical devices and so solutions are prepared and medical devices are immersed and removed from the solutions. The widespread use of OPA, and mode of use result in potential widespread worker exposure to OPA.

I would like to nominate the following chemical for which there is no Permissible Exposure Limit (PEL):

1-Bromopropane (n-Propyl Bromide).

I welcome the request for attention to the PELs seeking feedback from the broader community about concerns about work-related exposures to chemicals and the need for oversight and upgrading of PELs. I also appreciate the new thinking Eileen Senn and Matt Gillen have submitted for consideration for OSHA chemical regulation reform. Their proposals call for thinking beyond the traditional use of PELs for compliance. They identify the limitations of the current PELs, and the need to look at the hazards of the chemical, the potential for exposure (by multiple routes of entry) and consideration of the potential for harm, including multiple exposures and other stressors in the work environment.

If we retain exposure limits, we need to acknowledge that they are not the fine line that distinguishes healthy from dangerous, and use sampling as an indicator of progress in controlling exposures.

I agree with the need to find a way to combine exposures with the same or similar target organs and support comparisons to other existing occupational exposure limits. Updating of Skin notation would be welcome as well.

Please accept these recommendations from me as an individual. My experience has been shaped by my work at the Massachusetts Department of Public Health, Occupational Health Surveillance Program, and previously, at the Massachusetts Division of Occupational Hygiene, however, these are my opinions, and not a statement from any agency.

The OSHA PELs all require review and updating. I have limited these notes to a few chemicals; with more time I would expand this list. Among the chemicals of concern that I think need immediate attention are:

Lead: A 2007 article by Kosnett et al presents evidence that would support drastic reductions in the blood lead levels that would trigger protection. They propose that a single blood lead of 30 g/dL or two successive blood level concentrations measured over a 4-week period equal to or exceeding 20 g/dL should trigger medical removal protection. While the article does not propose a new PEL for lead, it would be assumed that the PEL would drop concomitantly to 20 g/m3. They propose these changes based on adverse effects of lead on blood pressure, renal function, cognitive abilities and female reproductive effects (e.g. spontaneous abortion and postnatal development delays in children born to women exposed to lead). These adverse effects have also been summarized by the California Department of Public Health. The current medical removal protection regulations are not adequately enforced. The PELs should be backed by more rigorous enforcement, including the MRPs. An article by Tak et al documented the absence of follow-up medical testing that is required before an overexposed worker is allowed to return to lead-exposed work. Changing the PEL or MRP concentration will not be sufficient to protect workers from the adverse effects of lead; increased penalties will also be needed.

Mercury: Mercury enters the body through inhalation and skin absorption. Mercury is still used in manufacturing of certain products in Massachusetts. OSHA s PEL is higher than the NIOSH REL and ACGIH TLV. Just this month, a company asserted that the exposure sustained by the employees is acceptable because it was in compliance. The excess risk posed by the sustained exposure and risk for pregnancy among employees was not acknowledged.

Asthma is a serious, widespread respiratory disease recognized as a critical clinical and public health problem in the United States (US). An estimated 16 million adults and 6.7 million children in the US have asthma. Asthma disproportionately affects people of color, with higher rates of asthma-related deaths, hospitalizations and emergency department visits. For example, Hispanics had higher rates of emergency department visits than did non-Hispanics, among adults with asthma (12.4 vs. 8.4 per 100 persons). Among adults with asthma, 40 to 50% reported that their asthma had been caused or exacerbated by work. . The role of chemicals in initiating asthma can be a crucial step in protecting adults from this prevalent and potentially disabling disease, and a number of chemicals have been reviewed and identified as asthmagens.

Diisocyanates, including MDI, TDI, HDI, etc. Use of isocyanates is increasing and their use is being promoted as a green solution to energy loss problems in residences and commercial properties (e.g. Icynene).

Glutaraldehyde. There is no standard for this chemical used as a cold sterilants for medical equipment.

Amine and anhydride hardeners in epoxy resins and isocyanate cured products. There are a number of diamines of concern.

Quaternary ammonium compounds, used as sanitizers and disinfectants. Production and use of these quats has been increasing with concerns about flu and other infectious diseases.

Nanomaterials are also of growing concern.

Kosnett MJ, Wedeen RP, Rothenburg SJ et al. Recommendations for medical management of adult lead exposure. Environ Health Perspect 2007. 115:463-471.

Tak S, Roscoe RJ, Alarcon W et al. Characteristics of US workers whose blood lead levels trigger the medical removal protection provision, and conformity with biological monitoring requirements,
2003-2005. Am J Ind Med 2008. 51:691-700

National Center for Health Statistics NCHS CDC. 2009. Summary health statistics for U.S. adults: National Health Interview Survey, 2007. Vital Health Stat 10(240). Summary Health Statistics for U.S. Children: National Health Interview Survey, 2007. Vital and Health Statistics. Series 10(239). [Accessed June 2009]

Moorman JE, Rudd RA, Johnson CA, King M, Minor P, Bailey C, Scalia MR, Akinbami LJ. National Surveillance for Asthma --- United States, 1980 2004. 2007.MMWR: Surveillance Summaries. 56(SS08);1-14;18-54.

Lutzker LA, Rafferty AP, Brunner WM et al. Prevalence of work-related asthma in Michigan, Minnesota, and Oregon. J Asthma 2010 Mar 47(2):156-61

Work-related asthma in Massachusetts: Population-based data from the 2006 & 2007 Behavior Risk Factor Surveillance System Asthma Call-Back Survey. Massachusetts Occupational Lung Disease Bulletin October 2008

Association of Occupational and Environmental Clinics

Data analyzed by the Toxics Use Reduction Institute, summarized in the Massachusetts Occupational Lung Disease Bulletin April 2010

Isophoronediamine, 1,2 cyclohexanediamine, hexamethylenediamine

As an oncology nurse for thirty years, I have been involved in handling hazardous drugs (HDs) such as chemotherapy. Many HDs are classified as known human carcinogens by the International Agency for Research on Cancer (IARC). Although OSHA published guidelines for the safe handling of HDs, these agents are often handled without appropriate precautions by nurses and pharmacists, resulting in low-level, but chronic occupational exposure.

I nominate the HDs that are classified as Group 1 IARC carcinogens as chemicals of concern. These drugs are: Azothiaprine, Cyclophosphamide, Etoposide, Melphalan, Chlorambucil, Semustine, Busulfan, Thiotepa, Treosulfan, Tamoxifen; and the combinations of drugs: Mustargen, Oncovin, Procarbazine, Prednisone (known as MOPP) and Etoposide, Cisplatin, and Bleomycin (known as ECB).

The criteria considered in selecting these chemicals include the fact that there are currently no PELs, no OSHA standards for handling, and that a significant number of healthcare workers are at risk for exposure and occupational illness. Healthcare settings are the only workplace settings where precautions used for the handling of known human carcinogens are determined by the employer. This lack of regulatory control places workers at risk.

The OSHA PEL for Manganese is grossly inadequate. While the OSHA limit is 5,000 ug/m3, the current TLV is 200 ug/m3, and the new proposed TLV is 20 ug/m3. This anachronism must be very quickly remedied.

I would like to nominate Asbestos and Anhydrous Ammonia. While these chemicals are typically popular for common industry use, it is my oppinion that the PELs for the exposure to employees needs to be revised. Thanks for your time.

OSHA's PEL for hydrogen sulfide is inadequate because it is based on a 1966 ANSI standard that was rescinded in 1969. Table Z-2 provides for a 20 ppm ceiling limit with a 50 ppm maximum peak exposure, which makes interpretation of the PEL confusing (i.e., combining a ceiling limit with a maximum peak limit). Currently, ACGIH recommends a time weighted average PEL of 1 ppm with a 5 ppm STEL. NIOSH recommends a ceiling limit of 10 ppm. NIOSH has identified 72 occupations with exposure to H2S in its Criteria for a Recommended H2S Standard and has stated that, for chemical exposures, H2S is one of the leading causes of sudden death in the workplace. It is a major safety and health issue for the wastewater treatment industry, oil and gas industry, and pulp and paper manufacturing industry. The ACGIH TLV may be overly conservative, but an update of OSHA's PEL for H2S is clearly warranted based on scientific research by Bhambani and others during the 1990's.

Nanoparticles. Please allow more direction for their safe use. As an institution of higher learning and research organization, our students working in labs see nanoparticles in consumer products daily and cannot equilibrate nanoparticles in the lab as being harmful or even as potential exposures. And, let's not forget about our researchers who guide the experiments and the students, they too need direction and sources of safe exposure levels.

The OSHA PELs (1910.1000) should also have designations for regulatory carcinogens and reproductive toxins (e.g., such as the California "Proposition 65" List). Moreover, with respect to carcinogen designations, I like the American Conference of Industrial Hygienists (ACGIH) approach (i.e., "A1" through "A5" categories). OSHA should consider adopting the ACGIH SENsitizer designation in the general PELs tables, and specify whether the chemical is a dermal and/or skin sensitizer. Finally, OSHA should update the list of chemicals with PELs for which a SKIN absorption designation is appropriate.

While OSHA has asbestos PEL regulatory limits, worker exposure continues today. Asbestos, a known human carcinogen, continues to be the leading cause of occupational cancers.

The Asbestos Disease Awareness Organization (ADAO) seeks the opportunity to work with OSHA to protecting workers occupational safety and health by increasing compliance of PEL regulations.

ADAO works closely with labor and occupational safety and health NGOs and can serve as a conduit for educational disseminations and program development.

About Asbestos Disease Awareness Organization

Asbestos Disease Awareness Organization (ADAO) was founded by asbestos victims and their families in 2004. ADAO seeks to give asbestos victims and concerned citizens a united voice to raise public awareness about the dangers of asbestos exposure. ADAO is the largest independent organization dedicated to preventing asbestos-related diseases through education and legislation. ADAO s mission includes supporting global advocacy and advancing asbestos awareness, prevention, early detection, treatment, and resources for asbestos-related disease. For more information visit

Veolia ES Technical Solutions is a recycler of mercury containing devices. We believe that a thorough review of the mercury exposure standard is necessary. Our experience with mercury demonstrates that compliance with OSHA regulations may not always be protective of employee health. We offer our active participation in the development of a new mercury standard to improve worker safety and health.

Please accept the following nominations for PEL reduction on behalf of the Building and Construction Trades Department, AFL-CIO:

1. Isocyanates (including MDI and TDI) exposure occurs in green construction during the use of sprayed-in insulation as well as in painting and various construction tasks. Manufacturers use a range of chemically and functionally similar ingredients that all have free isocyanate moieties but no PELs. Also with polymers like polyurethanes, the current PEL applies only to the monomer and not to multimers that still have free isocyanates ready to react with proteins to form an antigen that the immune system can respond to. These products are a complex mixture that must be addressed.

2. Fibers including fiberglass, man-made mineral fibers, and refractory ceramic fibers used to insulate homes and industrial processes. Some of these fibers are less soluble and therefore more persistent in the lungs. Ideally a standard would also address coatings and binders used to stick these together into batts, or in the case of blown in insulation to reduce settling. A common binder is formaldehyde-phenol resin, which can cause irritation and allergic responses. Multi-component products are poorly addressed with the current systems. As these fibers currently do not have PELs, OSHA should establish appropriate PELs for construction work.

3. Metals including manganese, nickel, vanadium and others are generated as dust and/or fume from welding, abrasive blasting and work in and around oil and coal power boilers. Given their toxicity and the extremely outdated PEL levels, OSHA should give priority to these metals. Manganese for example, has a ceiling limit of 5 mg/m3 which is 25 times the current recommended 8 hour TWA of 0.2 mg/m3 recommended by ACGIH.

Additionally, welding fumes in general should have a protective PEL based on recent science because research suggests that toxicity of welding fumes may be related not only to constituent metals, but also the extremely small particle size in fumes.

4. Mixed dusts. General construction dust exposures lead to COPD and other debilitating diseases. The Total Dust and Respirable dust PELs are too high.

5. High temperatures lead to an alarming number of illnesses and fatalities, and OSHA should consider establishing a protective PEL for heat.

6. Noise in construction must be regulated by both reducing the PEL and establishing a hearing conservation program.

7. Lead. There is ample scientific evidence the current PEL is not protective.

Hydrazines are a chemical of concern for some of my clients in research and testing of rockets, particularly because the PEL is below the odor threshold.

I have two chemicals I wish to add to the priority list. In my various roles as a safety professional I have personal experience with both of these materials.

Styrene The current PEL of 100 ppm TWA is significantly below that of the ACGIH value of 20ppm TLV. The PEL is below other recognized limits by other agencies and other state OSHA Programs. Styrene is one of the most widely utilized chemicals in the United States.

Welding Fumes - There is currently no PEL for welding fumes. The ACGIH TLV for welding fumes is 5 mg/m3. Since welding fumes are a complex mixture of various elements OSHA has chosen to regulate individual constituents, but the synergistic effects and the complex nature of welding fume exposures may create a significant health risk beyond these individual constituents. The number of employees exposed to welding fumes is significant. The testing to determine compliance with each individual constituent is expensive and burdensome for most employers. A general exposure PEL for welding fumes would significantly improve small business ability to determine risk exposures, and therfore the need for improved environmental controls.

The Massachusetts Toxics Use Reduction Institute (TURI) is able to provide the following information. This information does not constitute a recommendation about how to approach the task of updating PELs, but is provided as a resource.

Background information on TURA

TURA requirements apply to Massachusetts companies that fall within specified industry sectors, have ten or more full-time employee equivalents, and use listed toxic substances at or above reporting thresholds. As of 2008, the TURA list of Toxic or Hazardous Substances included 1,422 substances. In 2008, 530 facilities reported the use of 147 of these substances.

Reporting thresholds for most chemicals are 25,000 lbs/yr for facilities that manufacture or process a chemical, and 10,000 lbs/yr for facilities that otherwise use a chemical. Lower thresholds apply to EPA Toxics Release Inventory PBTs and to other chemicals designated as higher hazard substances under TURA (to date, this includes cadmium, cadmium compounds, trichloroethylene, and perchloroethylene as well as all listed PBTs).

Additional detail on TURA program requirements can be found in the statute, available at

Chemical Use Information
The Toxics Use Reduction Act (TURA) program receives annual chemical use reports from Massachusetts companies. All data presented below are drawn from Massachusetts Department of Environmental Protection (MassDEP), 2008 Toxics Use Reduction Information Release, June 2010, available at Additional information on chemicals reported under TURA can be obtained from the TURA data website at or by contacting the TURA program directly.

Information on chemical use may be one useful tool for priority setting in some cases. This information must, of course, be used in combination with hazard information and other relevant data.

Chemicals Used in Largest Quantities
The following list shows the 20 chemicals used in the highest quantities by facilities reporting under TURA in 2008. A limitation to the data presented here is that some facilities have claimed trade secret status for the data they have submitted. Three additional chemicals (Butyraldehyde, Sodium Bisulfite, and Vinyl Acetate) would appear in this top 20 list if these companies had not claimed trade secret status.

Chemical name (CAS #), quantity used in 2008

Styrene Monomer (100425), 248,489,268 lbs
Sodium Hydroxide (1310732), 71,892,770 lbs
Methanol (67561), 66,596,784 lbs
Hydrochloric Acid (7647010), 59,169,267 lbs
Sulfuric Acid (7664939), 22,891,570 lbs
Sodium Hypochlorite (7681529), 22,753,119 lbs
Formaldehyde (50000), 22,536,216 lbs
Toluene (108883), 21,632,679 lbs
Potassium Hydroxide (1310583), 17,003,241 lbs
Ammonia (7664417), 14,861,002 lbs
Zinc Compounds (1039), 13,155,278 lbs
Methyl Methacrylate (80626), 12,010,531 lbs
Nitrate Compounds (1090), 11,705,643 lbs
Chlorine (7782505), 11,391,221 lbs
Ethyl Acetate (141786), 9,645,742 lbs
Methyl Ethyl Ketone (78933), 9,218,848 lbs
Acetone (67641), 8,672,540 lbs
Diisocyanates (1050), 7,117,653 lbs
Toluene Diisocyanate (26471625), 6,865,641 lbs
Adipic Acid (124049), 6,578,028 lbs

Largest quantities generated as byproduct

The following list shows the chemicals that were generated as byproduct in the largest amounts in 2008. Two chemicals (Ethyl Acetate and Sodium Bisulfite) would appear in this list if trade secret data were included.

Chemical name (CAS #), quantity used in 2008

Sodium Hydroxide (1310732) 9,193,462 lbs
Nitrate Compounds (1090) 9,140,571 lbs
Ethyl Acetate (141786) 8,564,975 lbs
Toluene (108883) 6,714,291 lbs
Sulfuric Acid (7664939) 5,355,349 lbs
Methanol (67561) 4,161,793 lbs
Methyl Ethyl Ketone (78933) 3,661,924 lbs
Hydrochloric Acid (7647010) 3,565,947 lbs
Formaldehyde (50000) 2,686,832 lbs
Lead (7439921) 2,527,787 lbs
Acetone (67641) 2,222,279 lbs
Ethylene Glycol (107211) 1,753,509 lbs
N-Methyl-2-Pyrrolidone (872504) 1,459,706 lbs
Nitric Acid (7697372) 1,358,481 lbs
Copper Compounds (1015) 1,200,242 lbs
Dimethylformamide (68122) 1,087,401 lbs
Sodium Hypochlorite (7681529) 973,134 lbs
Potassium Hydroxide (1310583) 923,634 lbs
Phosphoric Acid (7664382) 734,282 lbs
Ammonia (7664417) 721,894 lbs

More Hazardous Chemicals and Higher Hazard Substances under TURA

The TURA program has created subcategories of the TURA list of Toxic or Hazardous Substances. These subcategories were created based on primarily hazard, not use, information.

The category of More Hazardous Chemicals includes those chemicals considered by the TURA Science Advisory Board to present a greater concern than other chemicals on the TURA list of Toxic or Hazardous Substances. This list is provided to industry as an informational resource, to help them make sound decisions when considering chemical substitutions. The list was originally developed using a modified Delphi method. More information on this process can be found in Toxics Use Reduction Institute, Categorization of the Toxics Use Reduction List of Toxic and Hazardous Substances March 1999, available at:

The following substances are designated as More Hazardous Chemicals :

2,4 Dinitrotoluene;
2,6 Dinitrotoluene;
4 biphenylamine;
Aluminum phosphide;
Arsenic compounds;
Beryllium and beryllium compounds;
Bis (tributyltin) oxide;
Bischloromethyl ether;
Cadmium compounds;
Carbon tetrachloride;
Chromic acid;
Chromium compounds (+6);
CI Direct Black 38;
CI Direct Blue 6;
Crystalline Silica;
Cyanide compounds;
Ethylene oxide;
Fluoroacetic acetic acid;
Hydrogen cyanide;
Hydrogen fluoride;
Lead compounds;
Mercury and Mercury Compounds;
Methyl parathion;
Methylene Chloride;
Mixed Dinitrotoluene; Nickel compounds;
Osmium tetraoxide;
Paraquat dichloride;
Selenium and selenium compounds;
Silver chromate;
Sodium Azide;
Sodium pentachlorophenate;
Sulfuric acid; Sulfuric acid (fuming);
Vinyl chloride

The category of Higher Hazard Substances is a smaller subset of the More Hazardous Chemicals list. These are chemicals that have been chosen by the TURA program for particular focus in allocation of program resources. These substances have a 1,000 pound reporting threshold (or lower thresholds for those that are PBTs), and may be associated with additional regulatory requirements in the future. To date, the TURA program has designated cadmium, cadmium compounds, trichloroethylene, and perchloroethylene, as well as all listed PBTs, in this category. The authority to place chemicals on this list was created in amendments to TURA adopted in 2006. Additional chemicals are considered for addition to this list each year.

Emerging substances of concern and additions to the TURA list

The TURA program has recently added n-propyl bromide to the TURA list of Toxic or Hazardous Substances.

In addition, the TURA Science Advisory Board is currently evaluating selected substances of emerging concern for possible addition to the list.

More information is available from TURI as needed.

Please consider performing a thorough investigation of Bis-Hexamethylenetriamine-CAS 143-23-7. This chemical is hygroscopic and is used in the paving industry. The LD50 is 450 mg/kg rat. The chemical has no PV method or validated method where it can easily be analyzed. Chemical manufacturers are not disclosing all the risks of the chemical.

Aminoethylethanolamine (AEEA). This is a teratogen and is used in paving additives. OSHA may want to consider re-reviewing this chemical for issuance of a PEL.

All of the Diisocyanates not yet regulated by OSHA, including:

Dicyclohexylmethane 4,4'-diisocyanate (hydrogenated MDI);
Hexamethylene diisocyanate (HDI);
1,6 Hexamethylene diisocyanated Based Adduct;
(includes HDI-Biuret trimer, and other polymeric forms of HDI, including isocyanurates);
Isophorone diisocyanate (IPDI);
Napthalene diisocyanate (NDI)

All are sensitizers; widespread use (for many of these); Oregon OSHA has regulate these since 1986

The 1910.1040 ethylene oxide (EtO) standard should be modified. Delete section (d) since it inhibits rather than protects workers. Section (d) mandates initial monitoring (d)(2) and then says that monitoring may be terminated (d)(4). The most worker exposure to EtO occurs in healthcare and medical device manufacture sterilization with EtO. Modern sterilizers, though generally well designed, like any complex equipment can and sometimes do fail and leaks do occur. If a workplace tests OK today, there is no guaranty that it will be tomorrow or in six months time. Complying with section (d), thus gives a false sensor of security and defeats the purpose of having more detailed requirements for carcinogenic gases and vapors such as EtO. At least periodic, and preferably continuous monitoring for EtO should be done in order for employers to comply with their duty to provide a safe work environment

[OSH Act 1950 sec. 5]. Continuous monitors for EtO are readily available from several manufacturers.

Benzine Exposure

We polled Region V Industial Hygienists for chemicals we often sample for, but rarely get exposures above the PEL -- but above the TLV or REL.

Carbon Monoxidel
Stoddard Solvent/Naphtha;
Hydrogen Chloride;
Sulfuric Acid;
Sulfur Dioxide;

There are now more than 70 reported cases of Parkinson's-like neurotoxicity in welders exposed to manganese from welding rods. In addition, I have two unreported cases and know of many more. I feel that the PEL for manganese is inadequate to protect from neurotoxicity and that MSDS's of welding rods need to be reviewed. ALOSH while studying this issue, has been underplaying the reality of the actual cases occurring which strongly suggest more personal monitoring is needed for welder safety.

1.       Acetaldehyde

HPV chemical (>100M-500M lbs)a. Identified carcinogen (IARC 2B; NTP Part B). High cancer risk. 210 cancers /1000 workers at current PEL.b 200 ppm PEL is based on conjunctivitis and sensory irritation. Flavoring agent. Potential for significant exposures.

PEL =1 ppm to reduce cancer risk to 1/1000.

2.       1-Bromopropane

New HPV solvent (>1M-10M). No PEL. Identified developmental, male, and female reproductive toxicant; neurotoxicant (NTP CERHR, Proposition 65 List); carcinogen (NTP draft). Peripheral neuropathy cases reported among workers. Widespread use as a degreaser; used in dry cleaning. Skin absorbable. Available in aerosol cans. Cal/OSHA PEL=5 ppm (Skin) based on protecting against developmental toxicity. PEL was derived using quantitative risk assessment based on NTP CERHR data. CA Dept. of Public Health Hazard Alert in 2003. Recommend 5 ppm PEL pending availability of cancer unit risk value.

3. Dibutyl Phthalate

HPV chemical (10M-50M). Identified developmental and male and female reproductive toxicant (NTP CERHR; Proposition 65 List)

High risk at current PEL of 5 mg/m3. Exposures occur in the manufacture of phthalates, rubber hoses, and rubber gaskets; and in nail salons. Recommend PEL = 0.01 mg/m3 to prevent developmental, and male and female reproductive damage. PEL is derived based on the critical study (Lee et al. 2004 Toxicology 203, 221-38) identified by the Cal/EPA Office of Environmental Health Hazard Assessment (OEHHA) in developing a Maximum Allowable Dose Level for DBP, and using standard QRA methodology with adjustments for occupational exposure.

4. p-Dichlorobenzene

HPV chemical (>50 M-100M lbs). Identified carcinogen (IARC

2B; NTP Part B). High cancer risk. 900 cancers /1000 workers at current PEL. 75 ppm PEL is based on eye damage, vertigo, and neuropathic effects. Insecticide and fumigant. Potential for high use and exposure. PEL = 0.1 ppm to reduce cancer risk to 1/1000.

5. Diesel Engine Exhaust

Identified carcinogen (IARC 2A; NTP Part B). Cancer risk. No PEL. Mechanics, bus drivers, toll booth operators, port workers, etc. potentially exposed. 2002 CA Dept. of Public Health Health Advisory and recommended PEL of 0.02 mg/m3 --used as reference for NIOSH HHEs involving diesel exhaust exposures. PEL=0.02 mg/m3 to reduce cancer risk to 1/1000.

6. 1,4-Dioxane

HPV solvent (>1M-10M lbs). Identified carcinogen (IARC 2B; NTP Part B). High cancer risk. 510 cancers/1000 workers at current PEL. Health basis for 100 ppm PEL is not clear. Skin absorption & inhalation. Used in paints & coatings.

High exposure potential. PEL = 0.20 to reduce cancer risk to 1/1000. Cal/OSHA PEL = 0.28 ppm

7. Ethylbenzene

HPV solvent (>1B lbs). Identified carcinogen (IARC 2B; NTP Part B). High cancer risk. 210 cancers/1000 workers at current PEL. 100 ppm PEL is based on irritation. Widespread use as a solvent and high exposure potential. PEL=0.5 ppm to reduce cancer risk to 1/1000. For more information on the derivation of the 0.5 ppm PEL see the Ethylbenzene PEL proposal document prepared for the Cal/OSHA Health Expert Advisory Committee at .

8. Ethylene Dichloride

HPV chemical (>1B lbs). Identified carcinogen (IARC 2B; NTP Part B). High cancer risk. 770 cancers/1000 workers at current PEL. 50 ppm PEL was derived from ANSI health basis unclear. Used as a degreaser, fumigant, solvent. Potential for high exposure. PEL=0.1 ppm to reduce cancer risk to 1/1000.

9. Flour Dust

Identified occupational asthmagen in US, UK, and Germany (Quint et al. 2008 AJIM 51:477-491). No PEL. Consider PEL=0.5 mg/m3 to minimize the potential for wheat flour sensitization in exposed workers. Will also help to prevent changes in lung function, increased prevalence of chronic bronchitis, and work-related respiratory and asthmatic symptoms (ACGIH 2001). PEL is based on epidemiological studies. No animal model for asthma-causing substances. QRA not used to derive PELs for asthmagens. Cal/OSHA PEL = 0.5 mg/m3 inhalable fraction based on asthma.

10. Glutaraldehyde

HPV chemical (1-10M lbs). Identified occupational asthmagen in US, UK, and Germany (see Quint et al. 2008 above). No PEL. Recommend PEL=0.015 ppm to prevent new onset asthma (based on an epidemiological data). Cal/OSHA identifies as asthma risk in footnote to PEL. 0.05 ppm Cal/OSHA PEL and ACGIH TLV are based on URT and eye irritation, CNS impairment, and skin irritation. There is a high potential for occupational exposure due to many industrial uses (cold sterilizer, biocide, tanning agent, preservative, etc.).

11. Hexahydrophthalic Anhydride, all isomers

HPV chemical (10M-50M lbs). Identified occupational asthmagen in US and Germany (see Quint et al. above). No PEL. Consider PEL=0.005 mg/m3 C to minimize sensitization from peak exposures when otherwise exposed to low or nonexistent airborne levels (based on ACGIH 2004). Workers exposed through use as curing agent in epoxy resin systems.

12. Hexamethylene Diisocyanate

HPV chemical (50M-100M lbs). Identified occupational asthmagen in US, UK, and Germany (see Quint et al. above). No PEL. Exposure during manufacture of polyisocyanate products used for various paint systems and

release of free monomer from paints and coating systems. Consider PEL=0.005 ppm (based on ACGIH 2001).

13. Isophorone Diisocyanate

HPV chemical (10M -50M lbs). Identified occupational asthmagen (see Quint et al. 2008 above). No PEL. Exposure during use in manufacture of polyurethane paints and varnishes and as an elastomer, and in release of monomer from paints and varnishes. Consider PEL=0.005 ppm (based on ACGIH 2001).

14. N-Methylpyrrolidone

HPV solvent (100M-500M lbs). Identified developmental toxicant (EPA, Cal/EPA OEHHA, Proposition 65 List, EPCRA 313 List). No PEL. Methylene chloride substitute. Significant use as a paint stripper, graffiti remover, electronics cleaner, and in other industries and products. Skin absorbable. High exposure potential. Recommend PEL=1 ppm (Skin) to protect against developmental toxicity. The PEL is derived using QRA based on key studies identified by Cal/EPA OEHHA in developing a Maximum Allowable Dose Limit for NMP. A 1 ppm PEL was recommended by the Cal/OSHA Health Expert Advisory Committee in 2009 ( ). The derivation of the QRA-based 1 ppm PEL is described in the PEL proposal document. Recommend PEL=1 ppm (Skin).

15. Naphthalene

HPV chemical (100M-500M). Identified carcinogen (IARC 2B; NTP Part B). High cancer risk. 310 excess cancers/1000 workers at current PEL. 10 ppm PEL is based on eye irritation and ocular effects. Potential signicant exposure from use as chemical intermediate, deodorant, moth repellant, and in fuel exhaust.

PEL =0.03 ppm to reduce cancer risk to 1/1000.

16. Natural Rubber Latex (as inhalable allergenic proteins)

Identified occupational asthmagen (see Quint et al. 2008 above). No PEL. Widespread exposure across multiple industries. Consider PEL=0.0001 mg/m3 based on respiratory sensitization (ACGIH 2007).

17. Nickel and Nickel Compounds

HPV chemical (>100M-500M). Identified carcinogen (IARC 1; NTP Part A). High cancer risk. 47 excess cancers/1000 workers at the current PEL. 1 mg/m3 PEL is based on dermatitis and pneumoconiosis. Potential significant exposures in several industries. PEL=0.02 mg/m3 to reduce cancer risk to 1/1000.

18. Perchloroethylene (Tetrachloroethylene)

HPV solvent (500M-1B lbs). Identified carcinogen (IARC 2B; NTP Part B). High cancer risk. 744 excess cancer/1000 workers at current PEL. 100 ppm PEL is based on CNS impairment. High potential for exposure. PEL=0.13 ppm to reduce cancer risk to 1/1000.

19. Propylene oxide

HPV chemical (>1B lbs). High cancer risk. 160 excess cancer cases/1000 workers at current PEL. 100 ppm PEL is based on primary irritation and CNS depression. Potential for exposure during use as a fumigant to sterilize packaged foods, to pasteurize raw almonds, and as a chemical intermediate. PEL=0.62 ppm to reduce cancer risk to 1/1000.

20. Refractory Ceramic Fibers

HPV chemical (> 150M lbs). Identified carcinogen (IARC 2B). No PEL. Cancer risk. Insulation material. Asbestos replacement. High exposure potential. PEL=0.5 f/cc to reduce cancer risk to 1/1000 is based on a quantitative risk assessment conducted by NIOSH. Cal/OSHA PEL=0.2 f/cc.

21. Toluene

HPV solvent (>1B lbs). Identified chronic CNS toxicant (EPA IRIS, 2005); developmental and female reproductive toxicant (Cal/EPA OEHHA, Proposition 65 List). High risk for chronic health damage (above endpoints) at current PEL. 200 ppm PEL is based on acute, CNS impairment. Recommended PEL=10 ppm (rounded from 11 ppm) based on chronic neurotoxicity. Will protect against developmental toxicity. The PEL is derived using QRA and is based on 10 occupational neurotoxicity studies identified by EPA (IRIS, 2005). The Cal/OSHA Health Expert Advisory Committee recommended a PEL of 10 ppm based on neurotoxicity. A PEL of 3 ppm was derived using QRA based on female reproductive effects (spontaneous abortions) in one study. See details of the PEL derivations in the HEAC Toluene PEL document available at

22. Trichloroethylene

HPV solvent (100M-500M lbs). Identified carcinogen (IARC 2A; NTP Part B). High cancer risk. 196 excess cancers/1000 workers at current PEL. 100 ppm PEL is based on CNS impairment; cognitive decrements; renal toxicity. High potential for exposure. PEL=0.5 ppm to reduce cancer risk to 1/1000.

23. Trimellitic Anhydride

HPV chemical (100M 500M lbs). Identified occupational asthmagen in US, UK, and Germany (see Quint et al. 2008 above). No PEL. Potential for exposure during use as a curing agent for epoxy resins. Consider PEL = 0.0005 mg/m3 (IFV) (Skin) based on respiratory sensitization (ACGIH 2007).

24. Wood dusts (soft, hard, and Western Red Cedar)

Identified carcinogen (IARC 1; NTP Part A). Identified occupational asthmagen in US, UK, and Germany (see Quint et al. 2008 above). 5 mg/m3 PEL based on non-toxic, respirable dust. High risk for cancer and asthma at current PEL. Potential for widespread and high exposures. No available unit risk value upon which to derive a PEL based on cancer. NIOSH identifies wood dust as a carcinogen and asthmagen. NIOSH REL= 1 mg/m3. However, the basis and derivation (whether QRA used) of the REL are not clear.

a. Based on EPA TSCA IUR data from 2002 and 2006

b. Derived using cancer unit risk values published by the Cal/EPA Office of Health Hazard Assessment and adjusting for the difference between environmental exposures and occupational exposures.

Mercer (formerly ORC Worldwide) appreciates the opportunity to provide input into OSHA s deliberations over the critical issue of the development of up to date permissible exposure limits (PELs) to protect workers from exposure to hazardous chemicals. Mercer s ORC Health, Safety and Environmental (HSE) Networks have for nearly 40 years specialized in providing a wide array of occupational safety and health and environmental consulting services to businesses operating in the U.S. and globally. Currently, more than 130 large (mostly Fortune 500) employers in diverse industries are members of our HSE Networks. The focus of these networks is to promote effective occupational safety and health and environmental programs and practices in business and to facilitate constructive communication between business and government agencies responsible for establishing national occupational safety and health and environmental policy. Our activities are based on the premise that providing safe and healthy working conditions is the mutual concern of employers, employees and government agencies.

Mercer would first like to request considerably more time to provide OSHA with substantive input into the agency s deliberations about what chemical substances should be considered for the development of PELs and the important related issues of what processes and criteria should be used both for selecting appropriate candidates and establishing the limits themselves. There are clearly no simple or obvious answers to any of these difficult problems providing a 10-day period for stakeholder input is wholly inadequate and will ill-serve both OSHA and the workers it is attempting to protect.

At the same time, Mercer is supportive of OSHA s desire to act with reasonable dispatch to collect data, information and views about how to begin the too-long stalled effort to provide improved protection to workers exposed to hazardous chemicals. The agency faces a daunting challenge and making inroads into meeting the challenge will take long term commitment, the dedication of significant resources and the development and application of creative approaches.

For purposes of these comments, Mercer would like to suggest some broad parameters for beginning to embark on a long-term effort to develop new PELs and keep them updated over time. First, Mercer does not agree with those who suggest that OSHA should abandon PEL-setting in favor of other approaches, e.g., reliance on the General Duty Clause, reliance on the Injury and Illness Prevention Program regulation under development within OSHA, reliance on some kind of control banding rulemaking or other similar generic approach.

We believe strongly that none of these other supposed alternatives is an adequate substitute for, nor do most of them negate the need for, appropriate reference occupational exposure limits. At the same time, some of the suggested alternative approaches may have roles to play in the overall scheme of protecting workers from hazardous chemicals. For example, an employer is more likely to be successful in controlling the risk of ongoing exposure to a chemical to a level below a PEL if there is a safety and health management system (or I2P2 ) in place that provides for periodic monitoring of risks and controls.

Second, OSHA needs to be clear about what it is trying to achieve. Clarity about its goals is essential both to OSHA s establishment of a viable process for setting new limits and to its determination of what chemicals to select for rulemaking. Mercer strongly believes that

OSHA s basic goal, at least in the relatively short term, should be to establish updated PELs for a significant number of toxic substances that will result in enhanced health protection for significant numbers of workers in a reasonably expeditious manner. To achieve this goal, it is Mercer s view that OSHA s focus should be to 1) establish a transparent and collaborative process, and criteria, for selecting chemicals around which a reasonable degree of consensus might be possible among affected stakeholders about the need to update an existing PEL (or to set a new PEL where there is none), and then 2) endeavor to engage in a simplified and expedited rulemaking process for the establishment of the PELs for the selected chemicals. The existing traditional statutory process under section 6(b)(5) of the Act for establishing comprehensive standards dealing with toxic material will always be available for complex or controversial factual, scientific, policy or legal issues requiring a detailed review of data and information with respect to health effects, risk assessment and feasibility. As history has shown, however, this traditional rulemaking approach will never get OSHA where it needs to be in terms of a addressing in a meaningful way the universe of toxic chemical exposures that confront workers.

The most critical step is establishing a process and criteria for selecting candidate chemicals. As a threshold matter, Mercer strongly believes that the development of such a screening process and the selection criteria for the candidate chemicals should be transparent and collaborative. Any hope for success in PEL-setting rests on early and continued public involvement and buy-in. Some criteria for evaluating whether a substance would be an appropriate candidate for simplified and expedited rulemaking to set an updated PEL might include factors such as:

Are there occupational exposure limits (OELs) in place as standards or guidelines in the US or internationally that are identical or similar to each other and significantly more protective than the PEL

Are these OELs supported by more recent health data than were used to establish the PEL

Are the science and other data supporting the OELs consistent in their findings and well-accepted; were quantitative risk assessments performed or do the data support risk assessment

Are the health effects from exposure to the chemical sufficiently serious to take action

Is the chemical in use today in the US in significant quantities and are significant numbers of workers exposed to levels exceeding the newer OELs

Is there sufficient information to determine whether compliance with the OEL would be practicable in the affected industries

These and other potential criteria should be carefully vetted and refined by OSHA and its stakeholders, but Mercer believes that it would not be exceedingly difficult to reach a reasonable consensus relatively quickly. Similar criteria could be adapted for a situation where there is no PEL currently in effect.

Once the screening criteria are in place and a process for reviewing specific substances has been developed, OSHA could begin making candidate selections and initiate the rulemaking process. Mercer would be pleased to discuss its ideas for how such processes might proceed in subsequent comments.

Mercer appreciates OSHA taking this next step in its efforts to protect workers from the risks of exposure to toxic substances and looks forward to continuing to work with the agency in this important area. We again recommend that OSHA extend the time period for input and provide more focused guidance as to its objectives.

Public Citizen appreciates the opportunity to comment on OSHA's request for assistance in identifying top chemicals of concern for potential rulemaking. We are heartened by OSHA's recognizance of its past shortcomings in setting adequate permissible exposure limits (PELs) and its apparent eagerness to correct this problem.

In determining which chemicals' PELs OSHA should reassess, we compared OSHA's current PELs with the recommended exposure limits (RELs) set forth by the National Institute for Occupational Safety and Health (NIOSH). We reviewed NIOSH's criteria documents, which recommend standards and actions for OSHA to implement to protect workers from dangerous chemicals. We then compared NIOSH's RELs with the PELs found in OSHA's standards at 1910.1000, tables Z-1, Z-2, and Z-3.

Public Citizen recommends that OSHA reexamine the existing PELs for chemicals that affect a large number of workers, PELs whose limits far exceed the RELs put forth by NIOSH, PELs that NIOSH has specifically mentioned as inadequate, and PELs for chemicals that are potential carcinogens. These chemicals are listed below. These recommendations are based on review of NIOSH criteria documents, though there are limitations on the applicability of this data. Because some criteria documents are several decades old, the number of workers exposed to these chemicals is likely outdated. Nonetheless, we believe that in some cases the numbers may have increased over the years as industries and America's workforce have grown, and we therefore believe the potential for exposure and harm to employees is still great.

Chemicals with Over One Million Affected Workers as of the Date of NIOSH REL Publication (Note also that three of these chemicals also have large disparities between PEL and REL)


Chemical; REL; PEL; Affected Workers; Year of NIOSH Report

Ethylene Dichloride; 1 ppm, 4 mg/m , 10-hr TWA; 50 ppm, 8-hr TWA; 2000000; 1978
2-Butoxyethanol; 5 ppm, 24 mg/m , 10-hr TWA; 50 ppm, 240 mg/m , 8-hr TWA; 1680768; 1990
Antimony; 0.5 mg/m , 10-hr TWA; 0.5 mg/m , 8-hr TWA; 1400000; 1978
Metalworking fluids; 0.4 mg/m , 10-hr TWA; None; 1200000; 1998
Respirable crystalline silica; 0.05 mg/m , 10-hr TWA; (10 mg/m )/(%SiO2+2); 1060000; 1974

Chemicals with a Large Disparity Between REL and PEL

Ethylene glycol monomethyl ether acetate; 0.1 ppm, 0.5 mg/m , 10-hr TWA; 25 ppm, 120 mg/m , 8-hr TWA; 9892; 1991
Ethylene glycol monomethyl ether; 0.1 ppm, 0.3 mg/m , 10-hr TWA; 25 ppm, 80 mg/m , 8-hr TWA; 130608; 1991
Ethylene glycol monoethyl ether acetate; 0.5 ppm, 2.7 mg/m , 10-hr TWA; 100 ppm, 540 mg/m , 8-hr TWA; 244639; 1991
Ethylene glycol monoethyl ether; 0.5ppm, 1.8 mg/m , 10-hr TWA; 200 ppm, 740 mg/m , 8-hr TWA; 247691; 1991

Chemicals Whose PEL Has Been Criticized by NIOSH as Inadequate

Chlorobenzene; No REL; 75 ppm, 350 mg/m , 8-hr TWA; Unknown; 1993
Ethyl ether; No REL; 400 ppm, 1200 mg/m , 8-hr TWA; Unknown; 1993

Chemicals That Are Potential Carcinogens

Acrylamide; No REL; 0.3 mg/m , 8-hr TWA; Unknown; 1991

We urge OSHA to reexamine its PELs for these chemicals. Recognizing that the rulemaking process and limited resources will prevent OSHA from establishing an adequate PEL for every dangerous chemical, we also support suggestions offered by other commentators for OSHA to explore additional ways for OSHA to require employers to limit the chemical exposure of employees more quickly, such as through expanded use of the general duty clause or increased industrial hygiene standards.

The National Healthy Nail Salon Alliance (the Alliance ) was founded in 2007 by the California Healthy Nail Salon Collaborative, the National Asian Pacific American Women s Forum, and Women s Voices for the Earth. The Alliance and its member organizations work to raise public awareness of salon worker health and safety issues, advocate for safer nail salon products, and push for greater regulatory and legislative protection of salon workers.

OSHA s request for nominations of new or revised PELs for chemicals of concern is a timely one since the growing nail salon industry is replete with products containing toxic chemicals, such as phthalates, toluene, formaldehyde, and other chemicals that are linked to negative health outcomes such as cancer and developmental and reproductive harm.

According to the EPA, as many as 155,000 people work in the United States as manicurists and pedicurists. (2) And that figure probably greatly underestimates the numbers; NAILS Magazine estimates that there are as many as 380,000 licensed nail technicians in the U.S. (3) Nearly 95% of nail salon employees and 94% of all customers are women, many of child-bearing age. Nail salon workers often work more than 8 hours per day for 6 or 7 days per week, for an average of 8 years. Many of the products that nail salon workers use on a daily basis contain multiple chemicals that are either known to cause adverse health effects or have not been tested at all. Small workplaces and inadequate ventilation exacerbate the effects of ongoing exposure to multiple toxic chemicals in nail salons. The little research available indicate that nail salon workers may be at increased risk of adverse health impacts such as decreased attention and processing skills or an increase in occupational asthma. In addition, women of reproductive age or who are pregnant may be especially vulnerable to the chemicals used in nail salon products.

Although we believe that the risk assessment process is incomplete and does not address many issues such as cumulative exposures and underlying health conditions, many existing PELs are out of date and do not protect against the chronic diseases like cancer and reproductive and developmental harm that are of concern to most workers, but are difficult to link to workplace exposures. Published studies that have measured the level of air contaminants, such as toluene and dibutyl phthalate, in beauty salons suggest that even when exposures are well below current occupational exposure standards, workers still experience related health problems. (4,5)

Therefore, the Alliance and the Collaborative nominate the following list of top chemicals of concern for new or revised PELs.

PEL Nominations for Top Chemicals of Concern

Toluene: Adopt PEL of 0.5 ppm to protect against spontaneous abortions and other serious and chronic health effects.

Toluene is in many nail products including polishes, nail strengtheners, cuticle treatments, base coats, and top coats. It evaporates as the nail polish dries, making inhalation the most common route of exposure for nail salon workers.

Exposure to toluene can cause headaches, dizziness, and fatigue. (6) At high levels of exposure, toluene has been found to be toxic to the kidney and liver. (7) In addition, CDC s Agency for Toxic Substances and Disease Registry fact sheet on toluene indicates that breathing high levels of toluene during pregnancy can result in children with birth defects and retards mental abilities and growth. (8)

Toluene is now listed (as of 2009) on the California Proposition 65 List as a reproductive toxicant in addition to a developmental toxicant. The new listing as a reproductive toxicant is based on pregnancy loss as identified by the American Conference of Governmental Industrial Hygienists (ACGIH). (9)

Many nail salon workers who become pregnant cannot afford to stop work in order to stop their exposure to dangerous chemicals. Instead, they have to stay on the job, possibly risking their own health and the health of their pregnancies and babies.

We recommend a toluene PEL that will protect workers from toluene-induced neurologic effects (i.e., impaired color vision, impaired hearing, decreased performance in neurobehavioral analysis, changes in motor and sensory nerve conduction velocity, headache, and dizziness).

We support the application of an intraspecies uncertainty factor of at least 3 to account for a potentially wide variation in worker response to toluene exposure. (10)

Additionally, the PEL for toluene should protect against spontaneous abortions. (11) A toluene PEL of no greater than 3 ppm as derived from the Ng, 1992 study would better protect nail salon workers, the majority of whom are of reproductive age.

But we also urge that the allowable toluene exposure level to workers be as protective as the standard for the general public under California s Prop 65. Using a NOEL of 500 ppm, and assuming a 1,000-fold higher exposure, the PEL adopted by OSHA should be no greater than 0.5 ppm. (12) Since some nail products are already toluene free, that standard is not only safer, but is clearly formulaically feasible.

We encourage OSHA to adopt a short term exposure limit for toluene - not just an 8-hour TWA and a ceiling level to better protect workers against exposures that are of shorter duration but of a higher and dangerous level.

Dibutyl Phthalate: Revise PEL to fully protect against reproductive and developmental harm.

DBP is used in many consumer products, including nail care products. (13) DBP is a plasticizer used to keep nail polish soft and pliable to prevent the polish from cracking and chipping. (14) Routes of exposure are through inhalation, ingestion, and absorption. Studies on animal prenatal phthalate exposure indicate that prenatal exposure to dibutyl phthalate can adversely affect reproductive development, particularly male reproductive development. (15)

Dibutyl phthalate (DBP) is listed on California s Prop 65 list as a developmental toxin in both males and females. (16) The California Office of Environmental Health Hazard Assessment (OEHHA) has set the maximum allowable dose level (MADL) for di(n-butyl)phthalate at 8.7 micrograms/day. This value is based on the reproductive effects of DBP as observed in the study in rats by Lee et al. (2004) . (17)

The U.S. Department of Health and Human Services, Agency for Toxic Substances & Disease Registry (ATSDR) has also classified DBP as a high priority chemical for study because of its widespread use and its reproductive toxicity. (18)

The current dibutyl phthalate PEL of 5 mg/m3 is based on old data generated by the American Conference of Governmental Industrial Hygienists (ACGIH). OSHA should take a precautionary approach to protecting the reproductive health of nail salon and other workers by adopting a new dibutyl phthalate limit based on its developmental and reproductive toxicity and DBP s MADL of 8.7 micrograms/day set by OEHHA.

Methyl methacrylate (MMA): Revise PEL to protect against asthma.

Lower existing OSHA PEL (currently 100 ppm based on irritation) to protect against asthma. See Association of Occupational and Environmental Clinics (AOEC) listing as an asthmagen that is present in artificial nail products. (19)

Ethyl methacrylate: Establish PEL to protect against asthma.

Establish PEL for ethyl methacrylate based on asthma since it is widely used as a substitute for MMA and has a similar chemical structure.

Ethyl 2-cyanoacrylate: Establish PEL based on its classification as an asthmagen by the AOEC. (20)

Hydroquinone: Revise PEL to protect against asthma or dermal sensitization. (21)

Titanium dioxide: Revise PEL to protect against cancer. (22)

Factors for Prioritization Include potential adverse effects on vulnerable populations such as nail salon workers, who suffer health disparities, among your priorities for selecting which chemicals to focus on first.

To conclude, the National Healthy Nail Salon Alliance and its member organizations urge OSHA to adopt new science-based, health protective PELs based on chronic illnesses such as asthma, cancer, and reproductive and developmental impacts and that take into account vulnerable workers such as nail salon workers. Thank you for your consideration.

The following comments are submitted on behalf of the American Public Health Association (APHA) Occupational Health and Safety (OHS) Section in response to OSHA s request to identify chemicals on which to focus in the development of PELs. They are based on relevant APHA policy statements and the expertise of Occupational Health and Safety Section members.

1. If OSHA is only developing PELs for chemicals, consider doing it:

by classes or families of chemicals, as opposed to individual substances;

for high production volume (HPV) chemicals (manufactured at a rate of more than one million pounds annually, and therefore likely to lead to wide-spread exposures);

for what others in the USA and elsewhere generally call chemicals of concern (the definition varies), in particular substances considered to be carcinogens, mutagens, those affecting reproduction and development (including trans-generational effects), and those causing asthma, allergies and sensitivities;

integrating considerations of occupational and environmental health to ensure that occupational exposures do not lead to adverse health effects considered unacceptable outside workplaces:

incorporating hazard reduction (as opposed to risk management) as a fundamental component to prevent the release of hazardous chemicals;

with requirements for preventive action at different levels before reaching the PEL and at and above the PEL (e.g., as in the lead regulation), where the goal clearly must be to reduce exposures without the use of personal protective equipment and other measures that simply limit the harm (e.g, the Belgium system); and

with requirements for innovation to develop, and, where available, to use less toxic alternatives, especially for chemicals of concern and substances for which a PEL does not exist or is based on health and/or safety effects other than those of concern (see above).

Examples of how to do this can be found within and outside the United States. There are lists of specific substances, classes of chemicals, and chemicals of concern, as well as approaches to prevention of exposure for some of them.

2. We believe that current PELs are out-of-date and inadequate. Examples of the desperate need for more effective ways to prevent chemical-related injuries, illnesses, diseases and deaths in the United States include:

There are 85,000-plus chemicals used or produced in the U.S., a number said to be growing by about seven each day. Little is known about the toxic effects of most of these substances, especially when they are combined in products or used simultaneously in the presence of other hazards (e.g., noise, radiation);

The focus on measurement often distracts from solutions and prevention, the ultimate goal of occupational health and safety activities. For example, OSHA and others have collected hundreds of thousands of samples without follow-up action to reduce or eliminate exposures;

The combination of what others call the:

data gap (e.g., producers are not required to generate and disclose information about chemical hazards, many chemicals have not been tested for their toxic effects individually or in combination), safety gap (the excessively high standard of proof required before government can act to protect public health, even for well-established chemical hazards), and technology gap (lack of market and regulatory drivers to encourage and support investment, research, and education in green chemistry, the design, manufacture, and use of chemicals that are safer for biological and ecological systems); and

Piece-meal approaches, such as work-related occupational exposure limits (OELs), focus on control and risk management . They miss the bigger picture of the life cycle of chemicals, often ignore effective prevention and hazards, and, in practice, treat occupational health and workers as less important than environmental health concerns and practices.

3. We recommend OSHA look to the significant work that has been done within the United States and elsewhere to integrate occupational and environmental health in regulatory activities and workplace practices. These governments, researchers, health and safety practitioners and organizations use the principles of public health, precaution and informed substitution. The results are solution-oriented, integrated and programmatic.

Examples of alternative approaches for effective prevention of work-related illnesses, injuries, diseases and death include:

control banding, which originated in the pharmaceutical industry;

the approaches developed by several U.S. hygienists that emphasize action based on the presence/absence of prevention measures, the physical state of a chemical, programmatic requirements, etc. (e.g., the work of Eileen Senn in New Jersey and that of Tony LaMontagne, Richard Youngstrom and others in Boston);

the Belgium government s approach to prevention of hazards and use of Malchaire s SOBANE method;

other European practices and laws, including:


Substances in Preparations in Nordic Countries (SPIN),

Chemsec s Substitute It Now (SIN) list, and

those mentioned in the book, Within REACH; and

finding alternative chemicals and processes using them, looking to:

green chemistry, particularly the recent regulation in California, activities within that state and Connecticut, the Warner Babcock Institute for Green Chemistry, and the Great Lakes Green Chemistry Network, the alternatives assessment method that the Massachusetts Toxics Use Reduction Institute (TURI) and the Lowell Center for Sustainable Production (LCSP) developed for the state of Massachusetts, other TURI and LCSP activities and materials (e.g., the cleaners and State Chemicals Policy databases), and the work of Clean Production Action, particularly its Green screen and related materials.

To accomplish these recommendations, we support OSHA increasing its co-ordination and collaboration with other agencies (e.g., those responsible for TSCA, NIOSH, EPA s Design for Environment). That will provide opportunities to better integrate their activities and approaches, and ensure that occupational health and safety is given the attention it requires to truly prevent and reduce job-related injuries, illnesses, diseases and deaths.

We hope these comments are helpful, and would like to follow up our brief response to this complex subject with further resources and detailed discussions.

manganese fume. Currently ACGIH and Cal OSHA recommend an 8 hour TWA of 0.2 mg Mn/m3, federal OSHA enforces as a ceiling limit of 5. I have conducted full shift dosimetry of welding fume many times in construction, and manganese often is present in significant quantities. Also, why doesn't federal OSHA have a total welding fume PEL This frequently would be exceeded during many general welding tasks

manganese fume: Recent toxicological research indicates that welders exposed to manganese fumes at concentrations exceeding the ACGIH TLV of 0.2 mg/m3 may be at risk for developing a variety of neurological disorders, including symptoms that resemble Parkinson s disease. (Reference: Bowler, Rosemarie, et al., Dose-effect relationships between manganese exposure and neurological, neuropsychological and pulmonary function in confined space bridge welders, Occ. And Env. Med, 2007, 64:167-177). The OSHA PEL is 5 mg/m3 (Ceiling).

Isocyanates: many isocyanates are in use and not regulated by OSHA. Regulating these by the cumulative reactive isocyanate components, rather than individual chemicals may be advisable.

Ammonia: I don't know any research on this, but I have been in 50ppm (current PEL) workplaces, and it is intolerably high exposure

The American Society of Health-System Pharmacists (ASHP) welcomes your invitation to help the Occupational Safety & Health Administration (OSHA) identify chemicals for which OSHA has no permissible exposure limit (PEL) and that are putting workers at risk for occupational illness. ASHP believes that the widespread use of hazardous drugs (as first described by ASHP and then the National Institute for Occupational Safety and Health [NIOSH](1)) and the potential worker exposure from such use merits OSHA consideration for development of PELs.

Workers may be exposed to a hazardous drug at many points during its manufacture, transport, distribution, receipt, storage, preparation, and administration, as well as during waste handling and equipment maintenance and repair. All workers involved in these activities have the potential for contact with uncontained drug.

Early concerns regarding the safety of workers handling potentially hazardous drugs focused on antineoplastic drugs when reports of second cancers in patients treated with these agents were coupled with the discovery of these mutagenic compounds or their metabolites in nurses who handled these drugs and cared for treated patients.(2,3) Exposure to these drugs in the workplace has been associated with acute and short-term reactions, as well as long-term effects. Anecdotal and case reports in the literature range from skin-related and ocular effects to flu-like symptoms and headache.(1, 4-12) Two controlled surveys have reported significant increases in a number of symptoms, including sore throat, chronic cough, infections, dizziness, eye irritation, and headaches, among nurses, pharmacists, and pharmacy technicians routinely exposed to hazardous drugs in the workplace.(13,14) Reproductive studies on health care workers have shown an increase in fetal abnormalities, fetal loss, and fertility impairment resulting from occupational exposure to these potent drugs.(15-18) Antineoplastic drugs and immunosuppressants are some of the types of drugs included on lists of known or suspected human carcinogens by the National Toxicology Program(19) and the International Agency for Research on Cancer.(20) Although the increased incidence of cancers for occupationally exposed groups has been investigated with varying results,(21,22) a formal risk assessment of occupationally exposed pharmacy workers by Sessink et al.(23) estimated that cyclophosphamide causes an additional 1.4 10 cases of cancer per million workers each year. This estimate, which considered workplace contamination and worker contamination and excretion in combination with animal and patient studies, was based on a conservative exposure level. Connor et al.(24) found greater surface contamination in a study of U.S. and Canadian clinical settings than had been reported in European studies conducted by Sessink and colleagues.(25-27) Ensslin et al.(28) reported an almost fivefold greater daily average excretion of cyclophosphamide in their study than that reported by Sessink. These later findings could add 7 50 additional cancer cases per year per million workers to Sessink s estimate. Subsequent studies (29,30) have confirmed substantial variation in surface contamination of antineoplastic drug vials, raising concerns about worker exposure.

In light of these findings, ASHP would suggest that hazardous drugs merit OSHA consideration for development of PELs. The Society has engaged in significant activities related to this topic, including authoring the ASHP Guidelines on Handling Hazardous Drugs and participating in the expert panel reviewing and recommending updates to the NIOSH list of hazardous drugs. In light of this experience, ASHP would welcome the opportunity to lend the expertise of the Society and its expert members to this activity.


1. National Institute for Occupational Safety and Health. NIOSH alert: preventing occupational exposure to anti-neoplastic and other hazardous drugs in health care settings. Appendix A. Drugs considered hazardous. (accessed 2010 Aug 30).

2. Harris CC. The carcinogenicity of anticancer drugs: a hazard in man. Cancer. 1976; 37:1014 23.

3. Falck K, Grohn P, Sorsa M et al. Mutagenicity in urine of nurses handling cytostatic drugs. Lancet. 1979; 1:1250 1. Letter.

5. Harrison BR. Risks of handling cytotoxic drugs. In: Perry MC, ed. The chemotherapy source book. 3rd ed. Philadelphia: Lippincott,

Williams and Wilkins; 2001:566 82.

10. Ladik CF, Stoehr GP, Maurer MA. Precautionary measures in the preparation of antineoplastics. Am J Hosp Pharm. 1980; 37:1184,1186.

11. Crudi CB. A compounding dilemma: I ve kept the drug sterile but have I contaminated myself NITA. 1980; 3:77 8.

12. Crudi CB, Stephens BL, Maier P. Possible occupational hazards associated with the preparation/administration of antineoplastic agents. NITA. 1982; 5:264 6.

13. Reynolds RD, Ignoffo R, Lawrence J et al. Adverse reactions to AMSA in medical personnel. Cancer Treat Rep. 1982; 66:1885. Letter.

14. Knowles RS, Virden JE. Handling of injectable antineoplastic agents. Br Med J. 1980; 281:589 91.

15. McFarlane A. Ophthalmic problems in staff handling cytotoxic drugs. Aust J Hosp Pharm. 1986; 16:145. Letter.

16. Curran CF, Luce JK. Ocular adverse reactions associated with adriamycin (doxorubicin). Am J Ophthalmol.

1989; 108:709 11.

17. McLendon BF, Bron AJ. Corneal toxicity from vinblastine solution. Br J Ophthalmol. 1978; 62:97 9.

18. Valanis BG, Hertzberg V, Shortridge L. Antineoplastic drugs: handle with care. AAOHN J. 1987; 35:487 92.

19. Valanis BG, Vollmer WM, Labuhn KT et al. Association of antineoplastic drug handling with acute adverse effects in pharmacy personnel. Am J Hosp Pharm. 1993; 50:455 62.

20. Hemminki K, Kyyronen P, Lindholm ML. Spontaneous abortions and malformations in the offspring of nurses exposed to anaesthetic gases, cytostatic drugs, and other potential hazards, based on registered information of outcome. J Epidemiol Community Health. 1985; 39:141 7.

21. Selevan SG, Lindbohm ML, Hornung RW et al. A study of occupational exposure to antineoplastic drugs and fetal loss in nurses. N Engl J Med. 1985; 313:1173 8.

22. Valanis BG, Vollmer WM, Labuhn KT et al. Occupational exposure to antineoplastic agents and self-reported infertility among nurses and pharmacists. J Occup Environ Med. 1997; 39:574 80.

23. Valanis BG, Vollmer WM, Steele P. Occupational exposure to antineoplastic agents: self-reported miscarriages and stillbirths among nurses and pharmacists. J Occup Environ Med. 1999; 41:632 8.

24. National Toxicology Program. Report on carcinogens, 11th ed. (accessed 2005 Sep 15).

25. International Agency for Research on Cancer. Monographs database on carcinogenic risks to humans. (accessed 2004 Nov 1).

26. Skov T, Lynge E, Maarup B et al. Risks for physicians handling antineoplastic drugs. Lancet. 1990; 336:1446. Letter.

27. Skov T, Maarup B, Olsen J et al. Leukaemia and reproductive outcome among nurses handling antineoplastic drugs. Br J Ind Med. 1992; 49:855 61.

28. Sessink PJ, Kroese ED, van Kranen HJ et al. Cancer risk assessment for health care workers occupationally exposed to cyclophosphamide. Int Arch Occup Environ Health. 1995; 67:317 23.

29. Connor TH, Anderson RW, Sessink PJ et al. Surface contamination with antineoplastic agents in six cancer treatment centers in Canada and the United States. Am J Health-Syst Pharm. 1999; 56:1427 32.

30. Sessink PJ, Boer KA, Scheefhals AP et al. Occupational exposure to antineoplastic agents at several departments in a hospital: environmental contamination and excretion of cyclophosphamide and ifosfamide in urine of exposed workers. Int Arch Occup Environ Health. 1992; 64:105 12.

31. Sessink PJ, Van de Kerkhof MC, Anzion RB et al. Environmental contamination and assessment of exposure to antineoplastic agents by determination of cyclophosphamide in urine of exposed pharmacy technicians: is skin absorption an important exposure route Arch Environ Health. 1994; 49:165 9.

32. Sessink PJ, Wittenhorst BC, Anzion RB et al. Exposure of pharmacy technicians to antineoplastic agents: reevaluation after additional protective measures. Arch Environ Health. 1997; 52:240 4.

33. Ensslin AS, Stoll Y, Pethran A et al. Biological monitoring of cyclophosphamide and ifosfamide in urine of hospital personnel occupationally exposed to cytostatic drugs. Occup Environ Med. 1994; 51:229 33.

34. Connor TH, Sessink PJM, Bruce R. Harrison BR, et al. Surface contamination of chemotherapy drug vials and evaluation of new vial-cleaning techniques: Results of three studies . Am. J. Health Syst. Pharm. 2005; 62: 475-84.

35. Schierl R, Herwig A, Pfaller A, et al. Surface contamination of antineoplastic drug vials: Comparison of unprotected and protected vials. Am. J. Health Syst. Pharm. 2010; 67: 428-9.

I nominate d-Limonene because it is used in many citrus based solvents. It reacts with air and forms an allergic sensitizer. Not aware of any OSHA PEL. It's also a suspicious compound because of it's target organ effects on lab animals.

OSHA PEL is outdated. Current data indicates adverse health effects at much lower exposures.

I propose that the OSHA focus include 1-bromopropane, aka n-propyl bromide, CAS 106-94-5. Due to cost and EPA regulation, since 2005, mfgs. of aerosol cleaners have been substituting it for previously inert CFCs. This may be creating health risks not clearly identified. A PEL is needed.

Testing of ozone output of Air Purifiers that are installed in the duct systems of the A/C units. There have been several regulations of stand alone ozone systems, but those companies have just taken their product and moved it to in duct to get away from those regulations. Thus the regulations are in place, but the manufacturers need to have the product third party tested and EPA results listed. The companies themselves do a poor job of self-regulating and claim their products produce lower levels of ozone then they claim. Ex. Electronic Air Cleaners, UV Air Purifiers using UVV wavelength, PHI Cell, etc.

Reduce the noise PEL to 85 dBA

Styrene - It's very frustrating to find that exposures are well in excess of the ACGIH limits and we have this PEL that is way to high. I have tried to require respirators and have not been successful.

Oil Mist/Cutting Fluids. Frequent employee complaint in machine tool shops, yet never above the PEL. NIOSH has recommendations quite good.

We need to develop a PEL for Ethyl methacrylate (EMA). Ethyl methacrylate liquid monomer was chosen as a substitute for Methyl Methacrylate (MMA) by the claim that it isn t as harmful as MMA. Although it is a widely used chemical in the nail salon industry, there were very few studies being done on the toxic effects of EMA to set the appropriate exposure limit for this compound.

The European Union Regulation for the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) went into effect on 1 June 2007 to protect human health, and to improve the legislative framework on harmful chemicals. REACH places responsibility on industry to manage the risks that chemicals may pose to worker health and the environment. REACH applies to all chemicals and particularly addresses Substances of Very High Concern (SVHCs) which are defined in Article 57 of European Community Regulation (EC) 1907/2006 ( the REACH Regulation ) and includes substances which are:

Carcinogenic, Mutagenic or Toxic to Reproduction in accordance with Directive 67/548/EEC, the Dangerous Substances Directive. (This directive was recently replaced by EU regulation (EC)1272/2008 on classification, labeling and packaging of chemical substances and mixtures, the CLP Regulation. )

Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB) according to the criteria in Annex XIII of the REACH Regulation.

Identified on a case-by-case basis from scientific evidence as causing probable serious effects to human health (e.g., endocrine disrupters).

It is recommended that OSHA monitor the REACH regulations and the European Chemicals Agency website ( for ongoing substances which may be restricted under REACH. OSHA should consider how these substances should be regulated with potential occupational exposures in the workplace.

The following is an overview of the current SVHCs:

Substance Name CAS No. Possible Uses

4,4'- Diaminodiphenylmethane (MDA), Carcinogen; 101-77-9; epoxy resin in printed circuit boards5-tert-butyl-2,4,6-trinitro-m-xylene (musk xylene), vPvB; 81-15-2; oils, consumer product manufacturing

Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins), vPvB; 85535-84-8; softener in PVC and chlorinated rubber, flame protection in plastics and textiles

Anthracene, Carcinogen; 120-12-7 Coloring materials

Benzyl butyl phthalate, Reproductive toxin; 85-68-7; Softener for resin, PVC, acrylic

Bis (2-ethylhexyl)phthalate (DEHP); 117-81-7; Plasticizer

Bis(tributyltin)oxide, PBT; 56-35-9; Fungicides, wood preservatives

Cobalt dichloride, Carcinogen; 7646-79-9; Chemical intermediate

Diarsenic pentaoxide, Carcinogen; 1303-28-2; Insecticides, herbicide, wood preservative, coloring and printing

Diarsenic trioxide, Carcinogen; 1327-53-3; Herbicide, wood preservative, production of special glass

Dibutyl phthalate (DBP), Reproductive toxins; 84-74-2; Softener in adhesives and Paper coatings; Insect protective agent for textiles


(HBCDD) and all major diastereoisomers:

Alpha-hexabromocyclododecane ((α-HBCDD)

Beta-hexabromocyclododecane (β-HBCDD)

Gamma-hexabromocyclododecane (γ-HBCDD), PBT; 25637-99-4 and 3194-55-6

134237-51-7, 134237-50-6, 134237-52-8; Flame protection and textiles

Lead hydrogen arsenate, Carcinogen; 7784-40-9; Insecticides

Triethyl arsenate, Carcinogen; 15606-95-8; Intermediate products in the semiconductor industry

2,4-Dinitrotoluene, Carcinogen; 121-14-2; coloring agent

Anthracene oil, Carcinogen; 90640-80-5;wood preservation, softener (rubber), biocides

Anthracene oil, anthracene paste, Carcinogen; 90640-81-6; wood preservation, softener (rubber), biocides

Anthracene oil, anthracene paste, anthracene fraction, Carcinogen; 91995-15-2; wood preservation, softener (rubber), biocides

Anthracene oil, anthracene paste, distn. Lights, Carcinogen 91995-17-4; wood preservation, softener (rubber), biocides

Anthracene oil, anthracene-low, Carcinogen; 90640-82-7, wood preservation, softener (rubber), biocides

Diisobutyl phthalate;84-69-5; Reproductive toxin, Softener, substitution of other Phthalates

Tris (2-chloroethyl)phosphate (TCEP); 115-96-8; Flame protection, softener

Aluminosilicate Refractory Ceramic Fibres, Carcinogen; High temperature isolation, fire protection

Zirconia Aluminosilicate, Refractory Ceramic Fibres; High temperature isolation, fire protection

Acrylamide, Carcinogen; 79-06-1 used for synthesis of polyacrylamides and grouting agent

Trichloroethylene; 79-01-6; Carcinogen, manufacturing of chlorinated and fluorinated organic compounds cleaning/degreasing of metal parts adhesive solvent

Disodium tetraborate, anhydrous; 1303-96-4

1330-43-4; 12179-04-3; Reproductive toxin, in detergents and cleaners, in glass and glass fibres, ceramics, industrial fluids, metallurgy, adhesives, flame retardants, personal care products, biocides, fertilizers

Tetraboron disodium heptaoxide, hydrate; 12267-73-1; Reproductive toxin.

Thank you for giving me this opportunity to bring these chemical substances of concern to your attention.

The following list contains substances that are very common and typically materials of concern to employees. I will not include those materials on which OSHA already has seperate and specific standards.

I do want to specifically state that OSHA was correct in proposing, several years ago, the comprehensive ACGIH List (TLV's and BEI's). The industry has lost significant time and resulted in uncessary exposures to employees as a result of that revised table being thrown out of acceptance. Just like OSHA has used references to ASTM, ANSI, and NFPA standards, the reference to the technically valid ACGIH values should have also been allowed. Requiring OSHA to self justify each compound was an unnecessary and significant hurdle. That decision was not in the best interest of keeping consistant with the mission of OSHA.

Here is a listing of substances that may be of interest due to the population of those exposed and their common presence. This list is not in any particular order:

Acetone,Acetonitrile, acrylamide, ammonia, aniline, arsenic, arsine, bromine, butyl acetates, butyl and various mercaptans, carbon black, carbon dioxide, carbon disulfide, carbon monoxide, chlorine, chlorobenzene, copper fume and dust, cyanides, ethyl acetate, ethanol, ethyl butyl ketone, ethyl ether, formic acid, grain dust, heptane (common aliphatic hydrocarbons), hydrogen sulfide, iodine, isopropyl alcohol, lindane, mercury, methyl alcohol, methyl isocyante, methyl chloride, methyl acetate, methyl mercaptan, methyl methacrylate, methyl ethyl ketone, naptha, coal tar, nitric acid, nickel, naphthalene, machine oil mist, ozone, phenol, phosphoric acid, phosgene, pyridene, portland cement, styrene, sulfur dioxide, sulfuric acid, tetrahydrofuran, toluene (all the BTEX set of crude oil VOC's), Turpentine, Xylenes, and zinc dusts.

This is just a quick to consider list. There are more to add.

Anesthetic gas, including isoflurane.

I wish OSHA would make a determination on BLEACH. This common household disinfectant is so over-used that it is making people sick.


I reside in a Senior Citizen HUD-assisted apartment building that has people cleaning the common areas, sometimes with BLEACH.

Bleach is usually confused as a "cleaning agent" and IT IS NOT A CLEANER - it is a disinfectant. They pour bleach on the floors and then run a mop over it and the fumes are disasterous. I have had Asthma attacks from the use of this product. It must be used in a well-ventilated area because of the toxic fumes. There needs to be a standard of use for this toxic chemical, and education is key to the successful use of this in public buildings.

We are all elderly, and some have COPD and Asthma and BLEACH triggers terrible breathing attacks and causes lung damage.

I have tried to explain to the "property Manager On-Duty", that this should not be used around the Elderly, and she does NOTHING to control or stop the use of this toxic chemical around us.

My Pulmonary doctor is furious and still nothing is done. Everybody passes the buck to someone else.

If I have to I will file a formal complaint against this corporation, and they will in-turn, try to evict me for anything they can concoct to get me out of here, labeling me a "troublemakere". I have witnessed this happening previously with another manager.

We even employ a Maintenance Manager and he does nothing to stop the use of Bleach for cleaning purposes.

There should be NONE on the carts so then it would not be used around us, and be used by only those who know how to safely use this toxic chemical.

Bleach is cheap - this is the major reason they use it. The cost as well as false advertising contribute to higher health care costs

because this toxic chemical injures people lungs, nostrils and sinuses.

I know you have bigger fish to fry, but the awareness of use of toxic chemicals and chemical combining in a Residential setting, both contribute to bodily injury and higher healthcare costs. I have had to see my doctors twice for this very reason in the last year!

Where does the responsibility fall If the manager, the corporation or the Maintenance Manager cannot or will not control the use of Toxic Chemicals where we live - then we have no alternative than to turn to you for help.

Thank you for allowing us to input information that may help others.

The crystalline Silica standard is out of date. It is a ubiquitous exposure issue, esp. in construction. The PEL is cumbersome and inpractical compared to the TLV or REL. There's no requirement for the employer to do an pre-assessment prior to exposure either. Make it simple and enforceable by using a single number, e.g.- 0.05 mg/m3 or 0.10 mg/m3 silica dust.

Gluteraldehyde and ortho-phthalaldehyde (OPA) disinfectants widely used in the Healthcare industry need both PEL's and NIOSH analytical methods developed. There is evidence of irritant and sensitizing properties of both these chemicals.


Noise and confined spaces in construction.

Hydrogen Sulfide: On June 1st, 2009 I had a medical event at work. I went to the nurse's station where she told me at first I was too hot, then took my vitals, and saw my heart rate was 144 and skipping every 4th ot 5th beat. The nurse then told me I had heart problems. My heart rate came down blood pressure returned to normal after she cooled me down with ice packs. I went to the doctor had blood work and ekg. All this was normal but I had a splitting headache that would not respond to any pain releavders. The nurse practioner I saw told me to stay off work for two days and they would set an appointment to see a cardiologist. I called a co-worker to inform him that the doctor's office had told me to stay home for two days before coming back to work. My co-worker informed me that shortly after I had left work a one million gallon tank had exploded in the area I had worked in that day. Eight days later I learned that the tank explosion was due to Hydrogen Sulfide gas. After looking at Hydrogen Sullfide symptoms on the internet I then knew what cause my medical event. No one ever called to tell me my medical event could have been contributed to Hydrogen Sulfide exposure. Their is a lot more to this story but I think Hydrogen Sulfide should be recorded in PPB not PPM. All Hydrogen Sulfide monitors should be live with OSHA, EPA, and their state enviromental agency. EPA should lift their administrative stay and Hydrogen Sulfide should be reported on the Toxic Release Invintory report. Today as I write my comments I have some numbness in the left side of my face, Toes on my left foot numb, and I just took my Luminol treatment to prevent my headaches. My doctor that is helping bring me out of this exposure is Dr. Kaye Kilburn in Pasadena, Ca. Dr. Kilburn would be an excellant resource to indentify top chemicals of concern. I will be glad to sign a medical release or share any documintation, pictures, or reports that I have. I hope what I have shared today will create a safer enviroment for those who will follow in our footsteps. Thank you for seeing their is a need to review the PEL limits and seeing a change needs to be made, Wayne

Another area the PELs are way behind consensus standards has to do with particle size-selective sampling. For example, while OSHA recognizes "total dust" (<= 100 um) and "respirable dust" (<= 4 um), ACGIH/ISO/CEN recognizes "inhalable" (<= 100 um), thoracic (<= 10um) and "respirable" (<= 4 um). Moreover, OSHA should recognize the new sampling methodology and equipment that go along with size-selective particulate aerosol monitoring. Thank you.

Carbon monoxide needs a lower PEL (8-hour TWA) and needs an instantaneous or 2-minute STEL. The PEL should be no higher than 35 ppm.