Editors' Column Here it
is in OSHA Regulations Challenge Analytical Chemistry The Occupational Safety and Health Act (1970) established regulatory agencies in two different governmental departments. The Occupational Safety and Health Administration (OSHA) is part of the Department of Labor. Its assignment is to set and enforce standards and to establish training programs for workers. It must consider economic and technical feasibility in the standard-setting process. The National Institute of Occupational Safety and Health (NIOSH) is included in the Department of Health, Education and Welfare. It has the responsibility for developing criteria on which standards can be set and for conducting basic research on health and safety issues. NIOSH is concerned only with the possibilities of a health problem and is not required to recognize the factors of technical or economic feasibility in making its recommendations. It therefore tends to recommend absolute protection. Until recently, OSHA concentrated on establishing safety rules because a considerable number of these already existed, could easily be adopted as federal standards, and are readily enforceable. Health problems present a more difficult problem since the issues are not necessarily clear-cut, and much skill is required in research and enforcement. Thus far, OSHA has promulgated three standards (out of 22 NIOSH-issued criteria documents) for hazardous materials: asbestos, vinyl chloride, and a group standard for 14 carcinogens. However, it has announced intentions of dealing with the 19 remaining NIOSH criteria documents. The majority of the 19 involve hazardous substances. There are also plans for OSHA and NIOSH to issue jointly mini-criteria documents for approximately 400 substances (assembled in 23 chemically related groups). These 400 substances are derived from the list of threshold limit values (TLV) contained in the Walsh-Healey Public Contracts Act of 1936 and incorporated as OSHA guidelines when the agency was set up. Two important elements in the criteria documents are analytical techniques and suggested levels of control. Just about everyone is or has been convinced of the need for controls.
Problems arise when the discussion turns to the level of control needed (e.g., TLV's). Industry prefers that the TLV's be as high as possible, whereas labor and environmentalists prefer that they be as low as possible. In addition to the threshold limit value, which is a time-weighted 8-hr exposure level, a standard can define other values that have to be considered in establishing monitoring procedures. For example, the proposed standard on inorganic arsenic exposure establishes three values. The first is the TLV. The second is a ceiling level and is based on a 15-min maximum exposure. And the third is an action level. The respective numbers for each level in the arsenic standard are 0.004, 0.001, and 0.002 mg/m 3 . The action level provides for biological monitoring and other precautions that would not ordinarily be used in monitoring the TLV, and the instrumentation for that monitoring would have to come into use the moment the atmosphere reading hit the action level value. The numbers given in the standards for each of the permitted levels are absolute numbers. Almost all of the regulations do not address themselves to the concepts of standard deviation or experimental error: concepts which are inherently important in any analytical measurement which would be the basis of enforcing the standard. Besides the lack of consideration of standard deviation and experimental error, the other analytical problem involved with the setting of OSHA standards is the detection limit. The amount of a substance that can be detected is constantly getting smaller as more sophisticated equipment is used in analytical research. Industry, in particular, is afraid that without the proper information on toxic levels in humans as opposed to animals, standards may be set which would be almost impossible to implement. It is easier to redefine a detection limit than to determine a level that is probably toxic to man. On the other hand, would it not be better to detect and remove the possibly dangerous substance before it is found to be toxic? However, would it be feasible? A. A. Husovsky
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ANALYTICAL CHEMISTRY, VOL. 47, NO. 8, JULY 1975 · 773 A
