Everyone knows that the permissible exposure limits or PELs set forth in various OSHA standards are pretty old (most have not been updated since 1971), and that we’ve learned a lot about chemical exposure and human health in the years since those PELs were originally published.  OSHA knows it, too.  Furthermore, of the thousands of chemicals in the workplace, OSHA has adopted PELs for less than 500 of these chemicals.  OSHA is looking for guidance on a better way to address these exposures.

On October 9, OSHA issued a “Request for Information on Chemical Management and Permissible Exposure Limits.”  As OSHA explained in its press release, the administration is “launching a national dialogue with stakeholders on ways to prevent work-related illness caused by exposure to hazardous substances.”  The first step is to collect information on the management of chemical exposure in the workplace.

Here are some options OSHA is considering, and questions OSHA is asking:

  •  How can OSHA streamline the updating of PELs, as new toxicological and other human health information becomes available?
  • Is a tiered approach to risk a more appropriate way to assess risk?
  • Are there ways of preventing or limiting chemical exposure other than or in addition to PELs, such as task-based approaches?

This is a great opportunity for manufacturers who make or use chemicals in the workplace to weigh in on waht they believe could be effective, and protective, ways of handling chemical exposure.

Responses to the RFI should be submitted as comments on Docket No. OSHA-2012-0023 at http://www.regulations.gov.  Comments are due May 5, 2015 (180 days from October 9, 2014).