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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.
June 16, 1997
Dear [Name Withheld]:
This letter is in response to your December 20, 1996, inquiry to President Clinton, describing your son's condition that you believe may have been caused by chemical exposure. Your letter was forwarded to the Occupational Safety and Health Administration (OSHA) for response.
In your letter you asked about an association between toluene and Pierre Robin Syndrome. Our research has shown that while some agents like vitamin A, vitamin B (folio acid) and some pharmaceuticals have been implicated in clefting, the present medical opinion is there is no link between toluene and Pierre Robin Syndrome.
Toluene has been present in the workplace for many years and, at the concentrations usually found, is considered an eye irritant hazard. OSHA established a Permissible Exposure Limit (PEL) for toluene in 1971 of 200 ppm to reduce the exposure to below what is considered the irritant level for most employees. The odor of toluene is detectable by most people at concentrations in the range of 10 ppm to 15 ppm (5 to 7.5% of the PEL), so awareness of its presence due to its odor does not indicate that the air contaminant levels are exceeding or even approaching the PEL.
Extremely high levels of toluene exposure have occurred among women who have sniffed glue while they were pregnant. Even at these extremely high levels, there have not been reports of Pierre Robin Syndrome among the children of these women. Although the causes of Pierre Robin Syndrome are not all known, the probable factors include genetic considerations.
We have been unable to identify the chemicals listed in your letter as Sprayon Bluing or Sprayon Bluing Remover in the Trade Name Index. However, since there is no known relationship between Pierre Robin Syndrome and industrial chemicals, knowing the product ingredients would be unlikely to add any further information. I do not think that toluene causes Pierre Robin Syndrome. I understand you have overcome very serious odds and wish you and your son the best for the future.
John B. Miles, Jr., Director
Directorate of Compliance Programs
Dear Mr. President,
My son was born with Pierre Robin Syndrome. He almost died. The doctors who worked on him did a remarkable job saving his life. He has had numerous surgeries and trauma. I was exposed at work to a product called Sprayon bluing and Sprayon bluing remover. I was also exposed to a coolant that was in the workplace at that time. The doctors didn't have the reason as to what caused this. Neither did I at the time. Since this happened, my company has been bought and sold a few times and now it is called Evergreen Packaging. This is a division of International Paper. We are now using a different type of coolant although we are still using Sprayon bluing and Sprayon bluing remover. This product now has the ingredients labeled on it and also warning labels. When my son was born my workplace was basically a High Production sweatshop with temperatures of 120 degrees in the summer common. This product that I used for several years didn't have any warning labels on it, didn't have the ingredients on it and was used very frequently by all the personnel in the shop. All we had in the shop at that time to cool ourselves off with were fans. The aroma from this product has a very sweet smell to it and was very noticeable in the workplace every day. Now its a different place to work. The building has been completely rebuilt, the air is cleaned hourly, management doesn't harass the employees much anymore, and the machines I work with, (CNC MACHINES) are more high tech. than manual. Being a person with some college, (about 2 years at a k12 tech. school), I should be content. But I'm not. Toluene is a chemical that is actually quite dangerous in certain settings and is certain to cause birth defects (gene damage). My son is now 15 years old with a slight speech problem and is on the straight and narrow. My employer has a person with the name of Ron Wood that works in the office. Dr. Ron Wood, a person who does research at the University of Virginia is familiar with toluene. I have read his papers on the Internet since I bought a computer for my family this year and looked up the chemical toluene. Right away, the information went to Dr. Wood. Ron Wood, who works at Evergreen Packaging, worked there when my son was born and still works there today. I have worked there for 22 years and my job is a lot more secure than it was then. Do you think toluene causes Pierre Robin Syndrome? If your family had to go through this Mr. President, what would you do? If you could find some free time for postal response, it would be sincerely appreciated.
Sincerely written by one of your greatest admirers and a humble American,