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 http://www.osha.gov.

July 31, 1986

Ron Palmer, D.V.M.
U.S. Air Force Hospital
Dyess Air Force Base
Abilene, Texas 79607-5300

Dear Dr. Palmer:

As I mentioned in our telephone conversation regarding the metabolism and sampling method for ethylene oxide, Robert Turnage of the [Directorate of Science, Technology, and Medicine] will forward a copy of the Occupational Safety and Health Administration's (OSHA) ethylene oxide standard, as well as information on the metabolism.

Following are three sampling methods that are used by OSHA's Salt Lake City Analytical Laboratory:

  1. Eight Hour TWA Passive Dosimeter. This method is both convenient and accurate. Studies comparing this method to the OSHA procedure (#2) show good correlation between the two.
  2. OSHA Charcoal Tube 1. You mentioned that you are using a dual charcoal tube method. This has the following disadvantages: requires refrigeration for transport, as opposed to OSHA's method, and required several samples; migration from one tube to the next occurs.
  3. Qazi-Ketham Charcoal Tube. This method utilized larger tubes that requires special holders and is more cumbersome than smaller tubes utilized in OSHA's procedure.

More information regarding sampling is included in OSHA's standard. If further detail (information on passive dosimeters) is required, I suggest you contact OSHA's Salt Lake City Analytical Laboratory directly. Their address is:

SLC Analytical Laboratory
[8660 South Sandy Parkway
Sandy, UT 84070-6424]

Sincerely,


Beth Henning, M.D.
Office of Occupational Medicine

[Correction 2/13/04]