thesynergist | NEWSWATCH
Cal/OSHA Proposes Revisions to Lead Standards
California’s Occupational Safety and Health Standards Board, the standards-setting agency within Cal/OSHA, has proposed regulations to lower the action level and permissible exposure limit for airborne lead in construction and general industry. The agency proposes to lower the action level from 30 µg/m3 as an eight-hour time-weighted average to 2 µg/m3 as an eight-hour TWA, and to lower the PEL for lead, calculated as an eight-hour TWA, from 50 µg/m3 to 10 µg/m3. Cal/OSHA explains in a public notice (PDF) that the new rulemaking was initiated in response to health-based recommendations made by the California Department of Public Health in 2010 and 2013 and is intended to maintain employee blood lead levels (BLLs) below 10 µg/dl. Existing regulations aim to maintain BLLs below 40 µg/dl. Cal/OSHA also seeks to reduce workers’ exposure to lead through the oral route and to expand requirements for blood lead testing of employees who work with lead. Proposed revisions to existing requirements that address these concerns include establishing general hygiene requirements when employees are exposed to lead, rather than when they are exposed to lead above the PEL, as well as increasing the frequency of blood lead testing for employees whose BLLs are at or above 10 µg/dl, compared to existing requirements that call for testing of individuals whose BLLs are at or above 40 µg/dl. Cal/OSHA’s proposal would also require monthly blood lead testing for workers whose airborne exposures to lead are above 500 µg/m3 as an 8-hour TWA, regardless of respirator use. The proposed revisions would also lower the BLL at which some employees must be offered at least annual medical examinations and consultations from 40 μg/dl to 20 μg/dl. An employee would be temporarily removed from work due to a high BLL, a practice known as medical removal protection (MRP), if their BLL is at or above 30 μg/dl, whereas existing requirements set the criteria for MRP at a BLL of 50 μg/dl. MRP would also be required for employees whose two most recent BLL measurements or average BLL within the previous six months is at or above 20 μg/dl. The criteria for employees on MRP to return to work involving lead would be changed from a BLL of 40 μg/dl to 15 μg/dl. “The proposed amendments are needed to adequately protect employees who have occupational exposure to lead,” Cal/OSHA’s notice states. “[R]ecent evidence demonstrates that even at exposure levels well below those currently allowed by the existing regulations, harmful health effects can occur.” Anticipated benefits of the lead proposal include a reduction in the number of workers who are exposed to harmful amounts of lead, decreased risk that workers exposed to lead will develop harmful health effects, and a reduction in take-home lead exposures among workers’ families and other household members, according to Cal/OSHA. The Occupational Safety and Health Standards Board accepted written comments on the lead proposal until April 20, 2023, and held a public hearing in Sacramento, California, on the same date. The text of the proposed regulation as it was provided prior to the comment deadline and public hearing is available as a PDF . For more information, see the Occupational Safety and Health Standards Board webpage on lead.
Call for Nominations: Safe-in-Sound Awards
Nominations for the annual Safe-in-Sound Excellence in Hearing Loss Prevention Awards are now being accepted. The awards are cosponsored by NIOSH, the National Hearing Conservation Association (NHCA), and the Council on Accreditation of Hearing Conservationists (CAOHC). Two awards are given: one for excellence and one for innovation. According to Safe-in-Sound Review Committee Coordinator Scott Schneider, CIH, judges for the excellence award consider what nominees have done to control noise levels in their workplace—such as purchasing quieter tools or equipment, regularly checking noise levels, providing effective hearing protection and annual hearing tests, training workers effectively on noise on and off the job, controlling noise to NIOSH-recommended levels, and evaluating their program each year. Those who wish to nominate another individual, group, or company must submit nominations by June 8, 2023. Self-nominations will be accepted through August 18, 2023. For information on how to submit a nomination, visit the Safe-in-Sound website.
NIOSH Revokes One Respirator Approval, Rescinds Another
NIOSH announced in March that it has revoked the respirator approval issued to LiveFree Personal Protection LLP and has honored the request of another company, RB Sigma LLC, to voluntarily rescind the NIOSH respirator approval issued to it.
As of March 1, any LiveFree Personal Protection LLP respirator marked with a NIOSH approval label with the number TC-84A-9293 is no longer approved by NIOSH, the agency explains in a notice published on its website. These respirators may no longer be used, manufactured, assembled, sold, or distributed. The agency’s notice directs individuals to contact LiveFree Personal Protection LLP for details related to the revocation of this NIOSH respirator approval.
The voluntary rescission of the NIOSH respirator approval issued to RB Sigma LLC affects respirators marked with the approval number TC-84A-9419. As of Feb. 15, respirators bearing this number are no longer NIOSH approved and may no longer be used, manufactured, assembled, sold, or distributed, according to a notice on the NIOSH website. The agency directs individuals to contact RB Sigma LLC regarding inquiries about the decision to voluntarily rescind this approval.
NIOSH’s certified equipment list no longer includes the approval numbers TC-84A-9293 and TC-84A-9419. The agency encourages respirator users and others to use this list to confirm testing and certification approval numbers, which are printed on NIOSH-approved respirators. The website of the agency’s National Personal Protective Technology Laboratory provides a list of additional guidance documents intended to inform users of respiratory protective devices.
OSHA, Inspector General Disagree on Recommended Improvements to Agency's Process for Addressing Complaints
OSHA should improve its procedures for interviewing complainants and witnesses when conducting workplace inspections and investigations, according to a report released by the U.S. Department of Labor Office of the Inspector General (OIG). The report, which examined 100 randomly selected cases of OSHA inspections conducted during fiscal years 2019 and 2020, sought to determine the extent to which OSHA ensured that complaints and referrals received by the agency were adequately addressed. According to the report, OSHA did not interview the complainant in half of the cases and did not obtain witness statements in 37 percent. Forty-one of 65 cases where interviews were conducted resulted in penalties or citations, and no penalties or citations were issued in five cases for which OSHA did not interview complainants or witnesses. OSHA’s case files did not contain evidence supporting the decision not to investigate in 11 of 30 cases where no inspection was conducted. In 10 percent of cases involving inspections, employers corrected hazardous conditions after the deadline identified by OSHA, while no documentation of abatement existed for 11 percent. OSHA’s response, included as an appendix to the OIG report, notes that the 100 audited cases represent less than 0.2 percent of the more than 62,500 cases the agency processed during fiscal years 2019 and 2020. According to OSHA, “fewer interviews occur when no violation is observed simply because there is less to inquire about.” The agency also notes that documentation to support its decision not to investigate a workplace is required only for formal complaints. The OIG report is available online as a PDF.
NIOSH Video Highlights Hazards of Fluid Transfers in Oil and Gas Extraction
A video published by NIOSH focuses on safe work practices for fluid transfers from storage tanks to tanker trucks in the oil and gas extraction industry. According to the video, at least 12 oil and gas workers died during 2016–2020 while transferring process fluids at well sites. Causes of death for these workers included cardiac events, combustion-related explosions, being struck by vehicles, exposure to hydrogen sulfide, and heat stroke. Hazards during fluid transfers include the inhalation of chemicals such as hydrocarbons and hydrogen sulfide, the creation of oxygen-deficient atmospheres, and the potential for fires and explosions. NIOSH’s video stresses that the source of these hazards is the transfer of any process fluid, including produced water, flowback fluids, condensate, and crude oil. Recommendations for controlling these hazards are discussed according to the hierarchy of controls.
The video can be viewed on NIOSH’s website.
European Agency to Evaluate Health Effects of Five Substances
The European Chemicals Agency (ECHA), which works to implement the European Union’s chemicals legislation protecting human health and the environment, has been tasked by the European Commission to evaluate the occupational health effects of five substances. These substances include 1,3-butadiene, which OSHA says is produced through the processing of petroleum; 4,4-isopropylidenediphenol, also known as bisphenol A; boric oxide and other compounds that release boric acid; 1,2-dihydroxybenzene, or pyrocatechol; and silicon carbide fibers. According to ECHA’s weekly e-newsletter, the scientific evaluations will be carried out under the EU’s carcinogens, mutagens, or reprotoxic substances directive, which covers health and safety risks related to occupational exposure to carcinogens, mutagens, or substances toxic to reproduction. ECHA projects that the evaluations will be finalized by February 2025 and that it may include proposals for occupational exposure limit values, biological limit and biological guidance values, or notations for the substances.
NIOSH describes 1,3-butadiene as a “colorless gas with a mild aromatic or gasoline-like odor.” OSHA’s permissible exposure limit for the substance is 1 part 1,3-butadiene per million parts of air measured as an eight-hour time-weighted average.
Bisphenol A is primarily used in making polycarbonate plastic and some epoxy resins, according to a NIOSH Science Blog post. NIOSH’s skin notation profile of bisphenol A explains that it is “potentially capable of causing adverse health effects following skin contact,” including skin allergy and photoallergy (). OSHA and NIOSH have not established exposure limits for bisphenol A.
The NIOSH Pocket Guide to Chemical Hazards entry for boric oxide states that symptoms of exposure to the substance include irritation of the eyes, skin, and respiratory system; cough; conjunctivitis; and skin redness. NIOSH’s recommended exposure limit for boric oxide is 10 mg/m3 as a TWA concentration for up to a 10-hour workday during a 40-hour work week. OSHA’s PEL is 15 mg/m3 as an eight-hour TWA.
Pyrocatechol is a “colorless, crystalline solid with a faint odor” that will turn brown in air and light, according to NIOSH. OSHA has not established a PEL for pyrocatechol, but the NIOSH REL is 5 ppm, or 20 mg/m³. NIOSH’s skin notation profile for pyrocatechol indicates that skin contact with the substance may cause adverse health including acute toxicity, skin irritancy, skin depigmentation, and skin allergy.
Exposure to silicon carbide, described by OSHA as “yellow to green to bluish-black, iridescent crystals,” may cause symptoms such as irritation of the eyes, skin, and upper respiratory system. OSHA’s PEL for silicon carbide is 15 mg/m³ (total dust) and 5 mg/m³ (respirable fraction), whereas the NIOSH REL is 10 mg/m³ (total dust), 5 mg/m³ (respirable fraction). Fibrous forms of the substance, including whiskers, carry an ACGIH threshold limit value of 0.1 f/cc for respirable fibers and a carcinogenic classification of TLV-A2, which denotes a suspected human carcinogen.
A table on ECHA’s website summarizes the agency’s other work related to OELs.
EPA Proposes Principles, Approach for Cumulative Risk Assessment
In late February, EPA published a set of principles for evaluating cumulative risks under the Toxic Substances Control Act (TSCA), a move the agency characterizes as a step toward “developing [its] capability under TSCA to examine risk to people from exposure to multiple chemicals with similar effects.” EPA outlines its approach for applying these new principles in an accompanying draft proposal for the cumulative risk assessment of certain phthalate chemicals undergoing risk evaluation.
According to the agency, phthalates are used in many industrial and consumer products. EPA is concerned due to phthalates’ toxicity and the potential for high exposure to these chemicals from their widespread use. EPA proposes to group the substances di-ethylhexyl phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), di-isobutyl phthalate (DIBP), dicyclohexyl phthalate (DCHP), and di-isononyl phthalate (DINP) together for cumulative risk assessment under TSCA because they are toxicologically similar and the U.S. population is co-exposed to them.
EPA’s proposed cumulative risk assessment principles and proposed phthalate approach are available for public comment. A public virtual meeting of the Science Advisory Committee on Chemicals will be held May 8–11 to peer review these proposals. The agency's draft documents are available from the EPA website.
OSHA to Modernize Voluntary Protection Programs
OSHA opened a comment period in mid-February as part of a project intended to modernize its Voluntary Protection Programs (VPP), which recognize employers and workers who have implemented effective safety and health management systems. VPP was formally established in 1982 and has grown to include approximately 2,200 organizations. According to OSHA, the program’s growth has made its administration more resource-intensive, complicating the agency’s efforts to ensure the quality of VPP applicants’ safety and health management systems.
OSHA sought stakeholder input on issues including how the program can help expand the use and effectiveness of safety and health management systems and whether particular categories of hazards should receive special attention in the VPP certification process. The agency’s goals for VPP include aligning the program more closely with recent occupational health and safety management practices and standards; expanding the number of VPP participants; and identifying ways that certified safety and health professionals, third-party auditors, and others can assist in ensuring the quality of VPP participants’ management systems.
More information can be found on OSHA’s website. The comment period closed on April 14.
PAPR-Related Notices Issued by 3M Scott Fire & Safety, Honeywell
A user safety notice from 3M Scott Fire & Safety and a market action notice from Honeywell were added in recent months to the respirator user notices page of the NIOSH National Personal Protective Technology Laboratory (NPPTL) website, which lists notices from manufacturers regarding conditions or risks that may exist with NIOSH-certified products. Both notices have to do with powered air-purifying respirator (PAPR) products.
The 3M Scott Fire & Safety user safety notice affects 3M Scott C420 PAPR blowers manufactured between August 2020 and September 2021. According to the notice, the manufacturer of these units has “identified a population of production with the potential for internal impeller disengagement from the blower motor,” which may result in loss of powered air. The manufacturer recommends quarantining affected units until they are repaired through a mitigation and repair plan established by 3M. Additional details are available in the user safety notice (PDF).
The market action notice published by Honeywell Safety Products has to do with the company’s PAPR cartridges with SKUs PA7DEHE and PA70VAGHE. Honeywell previously issued a mandatory stop-use notice for these products due to a quality issue that “could cause possible exposure to carbon and other substances, creating a potential safety issue for the user.” The company’s new notification states that it is replacing all unopened, unused cartridges produced before November 2022 that are affected by this issue. Information regarding the replacement process can be found in the market action notice (PDF).
These and other recent notices can also be found on the NPPTL website.
CSB Highlights Hazards of Emergency Discharges from Pressure Release Valves
In a safety alert released in March, the Chemical Safety and Hazard Investigation Board (CSB) urged companies to adopt safer practices for emergency discharges from pressure release valves. Pressure-relief systems are designed to protect equipment from unexpectedly high pressures by transferring hazardous materials to a safe location. But CSB’s safety alert highlights four incidents in which the venting of flammable, toxic, or hazardous materials resulted in fatalities or injuries.
In one incident, horizontal piping at a chemical plant in Pasadena, Texas, discharged flammable ethylene vapor near workers. Some were forced to jump from the second or third stories of the plant, while others were injured during the evacuation. In another incident, methyl mercaptan was released from a chemical manufacturing facility in LaPorte, Texas, causing the deaths of four workers. A third incident, in West Carrollton, Ohio, stemmed from the release of highly flammable vapor from a waste recycling process and led to a series of explosions. The fourth incident occurred at the BP refinery in Texas City, Texas, when a release of flammable hydrocarbons led to an explosion that killed 15 workers and seriously injured 180 people.
CSB’s safety alert recommends that facilities follow guidance from American Petroleum Institute Recommended Practice 521, Pressure-Relieving and Depressuring Systems, and API RP 14C, Analysis, Design, Installation, and Testing of Safety Systems for Offshore Production Facilities, and points to resources from the American Institute of Chemical Engineers. Facilities should also determine safe discharge locations for hazardous chemicals.
Download the safety alert as a PDF.