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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.
April 4, 2005
Mr. Farouk Shami, Chairman
Houston, TX 77090
Dear Mr. Shami:
Thank you for your January 25, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). We have received over 220 copies of this letter which have been signed both by you and individual hairdressers. The letter requests information on the safety of products used in the hairdressing profession. Your paraphrased statements and questions are provided below, followed by our responses.
Statement 1: Bleaches, perms, relaxers and hair colors contain ammonium hydroxide. Specifically, 5%-10% of ammonium hydroxide can be found in hair colors. Many hair salons apply 10-50 hair color applications within an 8-hour work shift. Based on our experience, it is our belief that one hair color application produces exposure to ammonia in excess of the OSHA permissible exposure limit (PEL) of 50 parts per million (ppm).
Question 1: How safe is it to work in a beauty salon using ammonia products?
Response 1: A search of OSHA's Integrated Management Information System (IMIS) has not shown any overexposures to ammonia in beauty salons. This system keeps track of all of OSHA's inspection and enforcement activities. Additionally, OSHA is not aware of any studies which were conducted to determine the effects of ammonia to hairdressers in beauty salons.
The National Institute for Occupational Safety and Health (NIOSH) has identified a number of occupations in which exposure to ammonia may occur. However, these occupations are primarily in the manufacturing and processing of ammonia-containing products. Enclosed for your information is a copy of NIOSH's Occupational Health Guideline for Ammonia.
Please be aware that exposures above OSHA's PELs are based on time weighted averages (TWAs). The TWA is an employee's average airborne exposure to a contaminant as measured over an 8-hour work shift. OSHA has set 50 ppm as the PEL for ammonia. Employees' exposures above this limit are associated with eye and upper respiratory tract irritation. In order to determine whether or not the PEL has been exceeded, an employer would have to conduct personal air monitoring during the course of the employee's 8-hour shift.
Statement 2: We are also concerned about exposure to electric magnetic fields (EMF) in beauty salons. In hairdressing salons 10-15 hair dryers may be in use at the same time. A single hair dryer emits 60 to 20,000 milligauss (mG) within 4 inches of proximity. In addition, the Environmental Protection Agency's (EPA's) safe level recommendation ranges from .5mG-2.5mG.
Question 2: How safe is it to work in such an environment using conventional hair dryers?
Response 2: Currently, there is no consensus on the potential health hazard from exposure to EMF radiation. As such, no OSHA PELs have been established. Enclosed for your information is a NIOSH Fact Sheet on EMFs in the Workplace.
We thank your for your interest in occupational safety and health. We hope you find this information helpful. Please share our response with the other hairdressers. In the future, should you or any of the other hairdressers wish to verify that the information herein remains current, or to access the referenced information, you may consult OSHA's website at http://www.osha.gov.
Richard E. Fairfax, Director
Directorate of Enforcement Programs