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.

Jun 3, 1985

Honorable Charles Wilson
Member, United States House of Representatives
Room 201
701 North First Street
Lufkin, Texas 75901

Dear Congressman Wilson:

Your letter dated April 4, to Mr. Bill Prendergast, has been referred to the Occupational Safety and Health Administration (OSHA) for reply to your constituents' requests for information about copper acetoarsenite.

Organic arsenic compounds such as copper acetoarsenite are regulated as a group under Subpart Z - Toxic and Hazardous Substances of 29 CFR 1910. The OSHA permissible exposure limit (PEL) for the organic arsenicals is listed in Table Z-1 of 1910.1000 as 0.5 milligrams of arsenic per cubic meter of air averaged over an eight hour work shift (see enclosed material).

OSHA does not have specific health and safety guidelines for the repair and cleaning of machines containing the copper acetoarsenite. However, the following rules should be followed when handling any arsenic compounds:

1. Do not eat, drink, smoke or apply cosmetics in the workplace.

2. Wear appropriate protective clothing such as coveralls, gloves, impervious boots, hat, goggles or a face shield whenever there is a likelihood of skin contact with arsenicals.

3. Wear a respirator if the airborne concentration of arsenic compounds exceeds the OSHA PEL.

4. Take a shower at the end of the work shift. Do not wear or carry any work clothing home.

We are enclosing information on the toxicity as well as the safe handling of organic copper arsenite for your information. Please ask your constituents to contact us if they have further questions on this subject.


Edward J. Baier
Director Directorate of Technical Support


May 2, 1985

Honorable Charles Wilson
Member, United States House of Representatives
701 North First Street, Room 201
Lufkin, Texas 75901

Dear Mr. Wilson:

This is in response to your letter of April 4, 1985, to William Prendergast, concerning your constituents' requests for information.

One request is for information on incinerator regulations for burning boxes, paper containers and like material. I believe the applicable regulation for new incinerators are the new source performance standards for incinerators (copy enclosed). Your constituent should know that implementation of these standards and any permitting requirements are conducted by state and local authorities. Thus, your constituent should contact state or local air pollution officials for more specific permitting requirements.

The second constituent request is for OSHA regulations or guidelines on copper acetoarsenite. A copy of your letter has been forwarded to the Occupational Safety and Health Administration for information on their regulations and guidelines.


Paul M. Stolpman
Office of Policy Analysis and Review
United States Environmental Protection Agency
Washington, D.C. 20160