NEWS OF THE WEEK
BENZENE, FORMALDEHYDE: Workplace exposure limits proposed A logjam appears to have broken at the Occupational Safety & Health Administration. Last week the agency issued two new proposed standards for workplace exposure to benzene and formaldehyde. In the eight years since President Reagan took office, it has issued only five healthrelated standards. For benzene, OSHA once again has proposed a permissible exposure limit of 1 ppm in air averaged over eight hours and an action level of 5 ppm. If workplace exposure is below the action level, employers do not have to meet the standard's proposed requirements for installation of engineering controls, provision of protective clothing and equipment, monitoring, or medical surveillance. The four principal industrial sectors covered by the standard are petrochemicals, petroleum refining, coke and coal chemicals, and tire manufacturers. The agency estimates that some 270,000 workers are exposed to benzene and says that at the current 10-ppm exposure level, the chemical presents a risk of 44 to 156 excess deaths per 1000 employees. The proposed 1-ppm level is expected to reduce this risk about 90%. As a result, an estimated 822 lives would be saved over a working lifetime. That estimate appears to meet the test set forth in a 1980 Supreme Court decision that o v e r t u r n e d OSHA's first, 1978 attempt to lower benzene exposure to 1 ppm. In its decision, the court said the agency had to prove, based on substantial evidence, that exposure to a chemical poses a significant risk of substantial health impairment before acting to lower exposure to that chemical. Neither the Chemical Manufacturers Association nor the American Petroleum Institute, which 4
December 9, 1985 C&EN
were parties to the suit that resulted in the overturn of the first standard, was prepared to comment on the new one at press time. OSHA says that because there is substantial controversy over formaldehyde's potential carcinogenicity to humans—the compound has been shown to cause nasal carcinomas in rats—it has proposed two regulatory alternatives. Under one, formaldehyde would be treated as a carcinogen. The exposure level would be lowered from the current 3 ppm to 1 ppm with an action level of 0.5 ppm with other requirements similar to those proposed for benzene. Alternatively, the agency says it
OSHA has one proposal for benzene . . . Exposure limit Current Proposed Action level Workers exposed Annual cost
10.0 ppm 1.0 ppm 0.5 ppm 270,000 $29 million
. . . but two options for formaldehyde Exposure limit Current Proposed Carcinogen Irritant Action level Carcinogen Irritant Workers exposed Costs Carcinogen Capital Annual Irritant Capital Annual
3.0 ppm 1.0 ppm 1.5 ppm 0.5 ppm 0.75 ppm 1.3 million
$57.8 million $28.3 million $38.9 million $17.0 million
might simply lower the exposure level to 1.5 ppm if the record developed during the rule-making procedure indicates that the primary health concern is mucous membrane irritation and sensitization. OSHA estimates that some 1.3 million workers are exposed to formaldehyde. But fewer than half are exposed to levels above 0.5 ppm and even fewer, primarily in the wood finishing, plastics, and synthetic resins industries, to levels above 1.0 ppm. Ronald Lang of the Synthetic Organic Chemical Manufacturers Association says he is in general agreement with the approach OSHA is taking toward regulating formaldehyde in that it is looking at the most probable risk numbers rather than the worst-case scenario, as most federal agencies have done in the past. However, labor unions that had sued the agency to force issuance of both standards, although pleased that the agency finally has done something, are very concerned because neither proposed standard contains the limits on short-term exposure levels that are present in the current standards for both chemicals. That means, they contend, that workers could be exposed to potentially lethal levels of the chemicals for short periods of time without any law's being violated. OSHA had been ordered by the U.S. Court of Appeals for the District of Columbia to propose the formaldehyde standard by Dec. 3—it just met that deadline. And the agency was to appear in federal appeals court on Dec. 11 in a suit by the United Steel Workers seeking issuance of the benzene standard. Separate public hearings on both proposed standards, which likely will be published in the Federal Register this month, are expected to begin next March. D
