40

GAYLA J. MCCLUSKEY

Occupational Exposure Limits

Warning sign. (Courtesy of Lydia Forte Roberts Photography, with permission.)

or more than half a century, the toxicology and industrial hygiene community and others have

used occupational exposure limits (OELs) to help to prevent work-related illnesses. The first attempt to formalize exposure controls occurred in 1946, when the American Conference of Governmental Industrial Hygienists (ACGIH) adopted 148 exposure limits. These exposure limits were initially referred to as maximum allowable concentrations. In 1956 the terminology used today, threshold limit values (TLVs), was introduced.4 Today, the practicing occupational health professional has a variety of exposure limits to use in assessing various exposures to chemical and physical agents. Although the objective of each limit may vary (for example, from protecting nearly all workers3 to ensuring that no employee will suffer diminished health10), the overall goal is to prevent occupational exposures that may result in adverse health effects. This chapter focuses on OELs developed by organizations in the United States. Other countries have also developed limits. For example, Germanys Commission for the Investigation of Health Hazards of Chemical Compounds in the Work Area has developed OELs known as MAKs 418

for 600 chemical compounds.6 Great Britain also has several hundred OELs. Some of these exposure limits have been approved by the United Kingdoms Health and Safety Commission, giving them the force of law. Others serve as recommendations made by Britains Health and Safety Executive.8 Most of the OELs developed in the United States have been essentially voluntary guidelines or recommendations. These include the following exposure limits:
G

OSHAs permissible exposure limits (PELs) The ACGIHs TLVs The AIHAs Workplace Environmental Exposure Level (WEELs) NIOSHs Recommended Exposure Limits (RELs) The EPAs New Chemical Exposure Limits (NCELs) Internal company standards developed by chemical manufacturers and users

These guidelines are based on industrial hygiene judgment using available toxicologic and epidemiologic research and data resulting from field activities and occupational health programs. They are generally set at levels where adverse

420

SECTION I / Occupational Toxicology

health effects are not expected to occur. The ACGIH is explicit in stating that the TLV it recommends are not fine lines between safe and dangerous concentrations or relative indices of toxicity, and that any user should be trained in the principles of industrial hygiene.3 The ACGIH also indicates that the limits should not be used as legal standards, although the current OSHA standards were largely derived from TLVs. OSHAs compliance procedures indicate that overexposure to a TLV could be considered a violation.12 In addition, several other countries have adopted the TLVs into law. The Occupational Safety and Health Act of 1970 established the National Institute of Occupational Safety and Health (NIOSH) to recommend standards and OSHA to promulgate and enforce standards.10 OSHA permissible exposure limits (PELs) are currently the only standards in the United States backed by the force of law. After passage of the OSHA act, the Secretary of Labor was given a 2-year window in which to adopt existing national consensus standards and any established federal standard. Since TLVs were included as part of the Walsh Healy Public Contracts Act, OSHA for the most part adopted the 1968 TLVs, which resulted in nearly 500 limits for approximately 300 chemical substances.13 These were established in 1971 and are based on data that were obtained primarily in the 1950s and early 1960s. Since its inception, OSHA has promulgated new PELs for only about two dozen chemicals over the last 30 years and has not updated the initial PEL list. In 1989, OSHA published a final rule revising 212 existing exposure limits and establishing 164 new OELs. Industry and labor groups challenged the proposed rule, and in 1992 the 11th Circuit Court of Appeals ruled that the agency did not sufficiently demonstrate that the proposed changes were necessary or that they were economically or technologically feasible.1 This decision to vacate both the new limits and the revised, more protective limits forced the agency to return to the use of the original 1971 limits, which are still in effect today. The various exposure limits other than the PELs are not subject to technological or economic feasibility tests. In addition, some TLVs have been challenged in recent litigation. The amount and nature of the information used to establish OELS vary from chemical to chemical, and some OELs are based on limited research data. And, because there are so few OELs, the vast majority of chemicals used in commerce have no recommended limit. That said, the few existing OELs are indispensable tools for the occupational health professional. However, they must be used and applied with the recognition that there are inherent limitations as well as benefits.

the burdens that were established by the Occupational Safety and Health Act and by other requirements that have been added to the standards development process over time. The legal criteria the agency must meet include proving that the hazards pose a significant risk of material impairment, that the standards and limits are technologically and economically feasible, and that the benefits are cost-effective. NATIONAL INSTITUTE OF OCCUPATIONAL SAFETY AND HEALTH NIOSH was formed to conduct research on the health effects of exposure and to develop criteria for dealing with toxic materials, including safe levels of exposure. In 1974, NIOSH joined OSHA in developing a series of occupational health standards for substances with existing PELs, known as the Standards Completion Program. This effort resulted in the development of 380 substance-specific draft standards with supporting documentation for use in promulgating new health regulations. Because of the requirements associated with standards setting, these documents and the RELs remain as recommendations today. They are updated periodically and are published annually in the NIOSH Pocket Guide. NIOSH also developed levels for the 380 chemicals at which exposure is considered to be immediately dangerous to life and health (IDLH). These are included in the Pocket Guide and are used for respirator selection.9 AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS The ACGIH is a membership organization that develops OELs. Three committeesthe Chemical Substances TLV Committee, the Biological Exposure Indices Committee, and the Physical Agents TLV Committeecreate the TLVs and BEIs. Candidate chemicals and physical agents are listed on a Notice of Intended Change for at least a year before adoption. New and revised TLVs and BEIs are approved by the ACGIH board of directors. The list is updated annually and includes TLVs for about 700 chemicals and 40 BEIs. AMERICAN INDUSTRIAL HYGIENE ASSOCIATION The AIHA, also a membership organization, began the use of a consensus process for the development of airborne chemical exposure limits (WEEL Guides) in 1980. The AIHA WEEL Committee concentrates on chemicals for which there are no existing guidelines and has developed guides for about 80 chemicals. The WEEL Committee makes every effort to cooperate with the ACGIH and similar organizations to avoid duplication. In addition, the AIHA first set emergency exposure limits in 1964 and formed the current Emergency Response Planning Guidelines (ERPG) Committee in 1987. Limits currently exist for more than 90 chemicals.5

Organizations That Set Exposure Limits

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION OSHAs track record in revising and setting new PELs has not been very effective. This is largely a consequence of

Occupational Exposure Limits / 40 421

ENVIRONMENTAL PROTECTION AGENCY The EPA recently began setting OELs under the authority vested in that agency by the Toxic Substances Control Act (15 USC s/s 2601). Anyone who plants to manufacture or import a new chemical substance must submit notice to the EPA. The EPA conducts a risk assessment and, if the agency determines that the chemical may present an unreasonable risk of injury via inhalation exposure, it will set a new chemical exposure limit (NCEL). These limits are for informational purposes only and are not legally enforceable limits. However, chemical manufacturers are bound by a TSCA Section 5(e) Consent Order to follow the agencys recommendations. Currently, more than 20 limits are posted on the EPA web site.7

where: TWA = time-weighted average concentration, usually in parts per million or milligrams per cubic meter. C = concentration of contaminant during the incremental exposure time. T = time, T1, T2, T3....Tn are the incremental exposure times at average concentrations C1, C2 + Cn. Eight hours is generally used as the denominator, as most standards are based on an 8-hour workday.14 The application of OELs to workers on work schedules significantly different than the 8-hour day, 40-hour week should be done only by industrial hygiene professionals.

CHEMICAL MANUFACTURERS AND USERS Chemical manufacturers often set OELs for the chemicals they manufacture or formulate. These internal limits are usually published on the material safety data sheet document (MSDS) provided to the customer.

8-HOUR TWA LIMIT Most exposure limits apply to the entire 8-hour workday. Using the TWA concept above, the resultant calculated concentration could then be compared with the various occupational exposure limits (OSHAs PELs, NIOSHs RELs, ACGIHs TLVs, AIHAs WEELs, EPAs NCELs, and industry standards). The averaging time for all of these is up to 480 minutes (8 hours) for a 40-hour work week, except for the RELs, which use up to 10 hours during a 40-hour week.

Definitions
The terminology used to define various exposure limits is fairly consistent among the organizations that set OELs. Specific definitions are provided in the following discussion, although readers should refer to the referenced documentation for the basis of each OEL.

SHORT-TERM EXPOSURE LIMITS TIME-WEIGHTED AVERAGE Many exposure limits are based on time-weighted average (TWA) calculations, which apportion the measured exposure to the time period in which the exposure occurred. Thus, an employee could be exposed to concentrations above or below the exposure limit during the workday. This practice is not intended to subject an employee to an unreasonably high level of exposure. The ACGIH has recognized that excursions above the exposure level should be held to reasonable limits. The ACGIH suggests that excursions during a workday may exceed three times the TLV-TWA for no more than a total of 30 minutes, and for no more than five times the TLV-TWA, provided that the TWA-TLV is not exceeded.3 In a typical workday, an employee is often exposed to several different short-term average concentrations as a result of changes in job assignment, processes, and ventilation conditions. The TWA method calculates the full-shift average concentration by weighting different short-term average concentrations by exposure time. The TWA can be calculated using the following formula: TWA = C1T1+C2T2+CnTn 8 hours The ACGIH defines a short-term exposure limit (STEL) as a concentration that would not result in irritation, chronic or irreversible tissue damage, or narcosis that would impair the worker or materially reduce work efficiency. These limits are set for chemicals that have recognized acute effects in addition to toxic effects that primarily are of a chronic nature. STELS are considered to be a requirement in addition to the TWA limits. A STEL is calculated as a TWA using an averaging time of 15 minutes. It should not be exceeded at any time during a workday, even if the 8-hour TWA is not exceeded. Exposures should not be longer than 15 minutes and should not occur more than four times per day, with 60 minutes between successive exposures.2

CEILING A ceiling limit (c) indicates a concentration that should not be exceeded during any part of a workday. According to OSHA, if instantaneous monitoring is not feasible, then the ceiling shall be assessed as a 15-minute time-weighted average exposure that shall not be exceeded at any time during the working day.12 The ACGIH indicates that the sampling time should not exceed 15 minutes, except for substances that may cause immediate irritation when exposures are short.2

422

SECTION I / Occupational Toxicology

SKIN NOTATION This notation appears with other exposure limits and indicates that a substance may be absorbed in toxic amounts through the skin or mucous membranes. OSHA, ACGIH, AIHA, and NIOSH exposure limits include this designation.

BIOLOGICAL EXPOSURE INDICES Technically not OELs, BEls are guidance values for assessing biological exposure results and are set for nearly 40 chemicals and chemical classes by the ACGIH. These values represent the levels of determinants that are most likely to be observed in specimens collected from healthy workers who have been exposed to chemicals to the same extent as workers with inhalation exposure at TLV levels. The exceptions are for chemicals with inhalation TLVs based on protection against nonsystemic effects such as irritation. In this case the BEls are necessary, as these chemicals have the potential for absorption via another route of entry (usually the skin).3

SENSITIZER NOTATION Both the ACGIH and the AIHA note chemicals that cause sensitization. For ACGIH, the designation SEN is used for these agents based on human or animal data.3 The AIHA uses two designations: DSEN indicates the potential for dermal sensitization resulting from the absorbed agent and ultraviolet light, and RSEN indicates respiratory sensitization.5

Summary
OELs are based on the concept of a doseresponse relationship between the chemical or physical agent and resultant health effects that results in the conclusion that there is a lower level of exposure where adverse health effects will not occur. They do not afford a fine distinction between safe and dangerous conditions, owing to individual susceptibility and other factors. OELs should be considered guidelines for good practice. Their application requires knowledge of the basis of the limit and an understanding of the methods and procedures for monitoring exposure. REFERENCES
1. AFL-CIO v. OSHA, 965 F2d 962 (11th Cir 1992). 2. American Conference of Governmental Industrial Hygienists: 2000 Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices. Cincinnati, Ohio, ACGIH, 2000. 3. American Conference of Governmental Industrial Hygienists: 2001 Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices. Cincinnati, Ohio, ACGIH, 2001. 4. American Conference of Governmental Industrial Hygienists on line: Available at http://www.acgih.org/About/History.htm/ 5. American Industrial Hygiene Association: The AIHA 2001 Emergency Response Planning Guidelines and Workplace Environmental Exposure Level Guides Handbook. Fairfax, Va, AIHA, 2001. 6. Deutsche Forschungsgemeinschaft: MAK and BAT Values 2001 (Report 37). Weinheim, Germany, Commission for the Investigation of Health Hazards of Chemical Compounds in the Work Area, 2001. (Available in the United States from John Wiley, 605 Third Ave, New York, NY 10158-0012.) 7. Environmental Protection Agency on line: Available at http://www.epa.gov/opptintr/newchems/ncelmain.htm/ 8. Health and Safety Executive: Occupational Exposure Limits 2001. Sudbury, Suffolk, U.K., Health and Safety Executive Books, 2001. 9. National Institute for Occupational Safety and Health (NIOSH): NIOSH Respirator Decision Logic (DHHS [NIOSH] Publication No

PHYSICAL AGENTS OSHA and the ACGIH set OELs for physical agents of an acoustic, electromagnetic, ergonomic, mechanical, or thermal nature. These limits differ from inhalation TLVs in that many are based on actual industrial experience and human experimental studies. The limits are not single numbers and should only be applied by users who have training and experience in the specific measurement and evaluation techniques.3

EMERGENCY RESPONSE LIMITS The following guidelines are technically not considered to be actual OELs but are important in emergency response planning. NIOSH, as part of the Standards Completion Program, developed values for chemicals that represented exposure levels that were immediately dangerous to life and health (IDLH). An IDLH levels is defined as a condition that poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects, or to prevent escape from such an environment. These limits are for a 30-minute period.9 The AIHA issues ERPGs, which are community-based exposure limits for use in planning for accidental chemical releases. They are intended to be used to assess the adequacy of preventative and response measures undertaken for chemical releases and transportation emergencies. The ERPGs include three levels for a 1-hour period at which progressive levels of adverse health effects are expected.5

Occupational Exposure Limits / 40 423

87-108, NTIS Publication No PB-91-151183). Washington, DC, NTIS, 1987. 10. Occupational Safety and Health Act, 29 USC Chap 15. 11. Occupational Safety and Health Administration: 29 Code of Federal Regulations, 1910. 1000. Washington, DC, OSHA, 1971. 12. Occupational Safety and Health Administration: CPL 2.445B Changes to the Field Operations Manual (FOM). Washington, DC, OSHA, 1993.

13. Olishifski JB: Fundamentals of Industrial Hygiene, 2nd ed. Chicago, National Safety Council, 1971. 14. Plog BA: Fundamentals of Industrial Hygiene, 4th ed. Itasca, Ill, National Safety Council, 1996.