How meeting occupational exposure limits may still result in a citation.

OSHA-logoThe Occupational Safety and Health Administration’s (OSHA) Act of 1970 set out to establish standards that would promote safe and healthful working conditions for employees.

While OSHA has made significant headway over the past four decades in reducing occupational risks and increasing workplace safety, much is to be done to bring these outdated standards into the 21st century.

In fact, Dr. David Michaels from the U.S. Department of Labor stated that “the intent of Permissible Exposure Limits (PELs) is to protect workers from the health effects of hazardous chemicals. Unfortunately, most of our PELs were adopted more than 40 years ago and new scientific data, industrial experience, and developments in technology clearly indicate that, in many instances, these mandatory limits are not sufficiently protective of worker health.”

In an effort to update their standards, OSHA is undergoing a multi-year Standards Improvement Project. The goal of the project is to remove or revise individual requirements within rules that are confusing, outdated, duplicative, or inconsistent.

By doing so, OSHA believes that the improved standards will better help employers to understand their obligations, promote safety and health for employees, lead to increased compliance, and reduce compliance costs.

When compliance could still result in a citation

liquid styreneEven though they are outdated, many employers strictly adhere to OSHA standards for chemical fume exposure. But what happens when these limits are not stringent enough and employees become ill?

This exact scenario happened to a Wisconsin-based fiberglass manufacturer who was recently cited for exposing their workers to styrene fume.

Current OSHA standards set a PEL for styrene fume at 100 ppm over an 8-hour work period.

To highlight just how outdated this standard is, in 1996 the styrene industry agreed to voluntarily adopt a more stringent exposure limit of only 50 ppm over an 8-hour work period; half of what OSHA currently mandates.

The National Institute for Occupational Safety and Health (NIOSH) also adopted an exposure limit of 50 ppm.

Upon receiving notifications that employees were becoming ill, OSHA visited the fiberglass plant and found that airborne concentrations of styrene fume measured 1.3 times the industry agreed upon recommendation of 50 ppm (approx. 65 ppm).

While the concentration level was within OSHA’s limit of 100 ppm, the company was still issued a citation.

How is this possible?

The ‘umbrella clause’

umbrellaThe fiberglass company was issued a citation for violating the General Duty Clause.

This clause can be considered an ‘umbrella clause’ because it is the overarching requirement that all employers must adhere to.

Section 5 of OSHA’s Act of 1970 details the general duty clause which states in part:

Each employer –

(1)   Shall furnish to each of his employees, employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

In this case, while the company was well below OSHA’s styrene exposure guidelines, the exposure level was still high enough to where employees were getting ill; thus violating the general duty clause.

Proactive protection measures

Guard employee health before they become ill by implementing proper engineering safety controls that capture and filter harmful chemical fume before it has the opportunity to enter the ambient air.

In doing so you will not only better protect your workers, but you will help decrease your chances of violating the general duty clause.

Using local ventilation is a critical component to any comprehensive safety plan.

Sentry Air Systems offers a complete line of engineering safety controls and filtration systems that offer exceptional fume protection.

Available in a variety of sizes, configurations and mounting options, our chemical fume extractors come equipped with heavy-duty activated granule carbon filters that adsorb chemical fume molecules within the granule’s porous structure.

Sentry Air Systems Chemical Fume Extractors

The carbon filters also work in combination with a HEPA particulate filter that traps particles at the source of emission.

View a demonstration of how our activated carbon filters work in this YouTube video. You can also get a general idea of how effective our carbon filters are against certain chemicals by referencing our Activated Carbon Adsorption Ratings Chart.

Discuss your options

If you seek a chemical fume extraction system for your workplace, contact Sentry Air Systems and speak with one of our technical applications specialists. They will work with you in determining the most appropriate system. Call 800.799.4609, email sales@sentryair.com, visit our website or fill out the feedback form below.