An industrial hygienist's perspective on generic standards.
OSHA and EPA regulations promulgated to date contain the necessary framework to consider generic standards in the 1990s. Missing in OSHA standards has been the requirement for a competent person to define and manage an occupational health program and the requirement for all employers who have toxic materials with significant exposures to have a basic occupational health program. Certainly we have evolved to a point where every worker significantly exposed to toxic materials has a right to know what that exposure is. Fundamental to generic standards is the need to define what is meant by toxic substance and significant exposure level. It is suggested that NIOSH maintain a list of recognized safe exposure levels that have been recommended by credible organizations including NIOSH. It is suggested that action levels be defined as one-half the lowest recognized safe exposure level. It is proposed that all employers be required to conduct an initial inspection of their workplace, using competent persons, to determine if exposures exceed action levels. This is only one step beyond the requirements of the OSHA Hazard Communication Rule which requires that employers identify and maintain a list of all hazardous materials known to be present in the workplace and to inform workers of the hazards. If exposure levels are found in excess of action levels, then the basic elements of current standards would be required, including regular employee-exposure monitoring, medical surveillance, sanitation, training and education, and a management plan.
Lee
J S
JS
Rocky Mountain Center for Occupational and Environmental Health, University of Utah, School of Medicine, Salt Lake City 84112.
D001194:Asbestos; D001195:Asbestosis / Q000517:prevention & control; D002273:Carcinogens / Q000592:standards; D006801:Humans; D009316:National Institutes of Health (U.S.); D009787:Occupational Medicine / Q000331:legislation & jurisprudence / Q000592:standards*; D014116:Toxicology / Q000592:standards; D014481:United States; D014484:United States Environmental Protection Agency; D014489:United States Occupational Safety and Health Administration
D002273:Carcinogens; D001194:Asbestos