Archived Newsletters
Cal/OSHA Proposed PEL for n-propyl bromide and other chemicals, Part 2 - Your Immediate Actions
Barbara Kanegsberg and Ed Kanegsberg
Cal/OSHA developed an excellent PEL process; Ask them to use it.
Written comments
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Fax:(916) 274-5743
Standards Board's Office
2520 Venture Oaks Way Suite 350
Sacramento, CA 95833
Comments are requested by March 13, 2009 and must be received prior to 5:00 P.M. on March 19, 2009
Public meeting
March 19, 2009, at 10:00 a.m.
Costa Mesa City Council Chambers,
77 Fair Drive, Costa Mesa, California 92626
Cal/OSHA has proposed a PEL of 5 ppm for nPB; and they propose to lower the PEL’s for other chemicals/materials.
Workers and manufacturers are entitled to thorough, scientific, and transparent evaluations of all industrial chemicals of interest, including nPB.
The documentation and rationale needs to be more clearly stated than in the Cal/OSHA reports that we have found dating back to 2004 and 2005. The documentation needs to be more clearly stated than is apparent from the summary recently provided by Cal/OSHA. As scientists, we have difficulty grasping the basis for the uncertainty factors that were used to set the proposed PEL. It is curious that we do not find formal, public discussions about nPB between 2005 and the 2009 proposal.
A PEL process, one with stated underlying transparency, one requiring a well-documented and readily available reporting format, has been in effect for over a year. Cal/OSHA should use that process to evaluate the impact of nPB on the workforce.
Assess the potential impact on your product
Do you use nPB? Do your suppliers use nPB? What alternatives might suit your requirements.
Plan ahead. Determine if nPB is used for industrial cleaning, critical cleaning, or precision cleaning . Consider the impact of a 5 ppm PEL. Determining where you use nPB is important if you have cleaning activities as part of manufacturing, assembly, restoration, or maintenance. It is especially important if you have reliability and performance concerns.
The bottom line: we urge you to take an active role. Contact Cal/OSHA; urge them to use the new PEL process with nPB and with all chemicals under consideration.
As always, please feel welcome to contact us and provide your feedback.
Reference
“Compelling PELS”
http://www.cemag.us/articles.asp?pid=798
