OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 10, 1984

Ted B. Ulanday, M.D.
509 E. Santa Clara Street
San Jose, CA 95112

Dear Dr. Ulanday:

This is in response to your letter of September 25, 1984 wherein you requested information on hazards regarding dry photocopiers.

The National Institute for Occupational Safety and Health (NIOSH) performed a Health Hazard Evaluation (HHE) at Sperry- Univac Corp., Blue Bell, Pennsylvania in 1976 at the request of clerical employees who worked in proximity to office copiers. These workers reported symptoms such as respiratory and eye irritation, headache, sore throat, and fatigue.

A variety of copiers were in use at this facility, including models that operated on dry toner (Remington 530). NIOSH performed air sampling to determine the concentrations of ozone and toner dust in areas surrounding these machines.

The dry toner, in this case, was composed of 10 percent carbon black pigment and 90 percent resinous co-polymeric hydrocarbon. Exposure levels to carbon black were found to be well within the current OSHA exposure limit to 3.5 milligrams per cubic meter of air. It should be noted that evidence demonstrates that inhalation of carbon black dust does not result in the types of health effects exhibited by the affected workers.

Ozone concentrations were found to range from zero to 0.2 milligrams per cubic meter of air in areas around the Remington 530 copiers. The OSHA exposure limit for ozone is 0.2 milligrams per cubmic meter (or 0.1 part per million parts of air). Although responses may vary between individuals, it is possible for exposed persons to experience headaches, irritation of the eyes, and dryness of the nose and throat at very low concentrations.

In the absence of more specific information concerning the conditions under which your patient may have been exposed, it is difficult to draw any conclusions. Furthermore, environmental testing would be necessary to document the presence of suspected air contaminants.

Enclosed is a copy of the NIOSH/OSHA health hazard guideline for ozone. A more extensive discussion of ozone and its effects is covered in Patty's Industrial Hygiene and Toxicology, 3rd revised edition, by Frank A. Patty, pp. 4067-4094, 1982.

If we may be of further assistance in this matter, please do not hesitate to contact us.


Regional Industrial Hygienist