This column updates the May 2010 column, and January 2011 column in which I reported on a whipsaw (a lose-lose situation) faced by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA). OSHA’s core problems are: (1) the uncontrollably high cost of resources and time required to produce credible permissible exposure limits (PELs), which limited its ability to comply with international treaty agreements, and (2) the growing belief that PELs are not an effective tool in managing the health of industrial workers. In both columns I said that I would keep you informed. This column is an update based on OSHA’s web-based Q&A session on January 5, 2011.

THE PRACTICE
Many observe that industrial hygienists have a standard operating practice of conducting a site inspection: (1) show up, (2) note the site’s inventory of chemicals from hazard communication files, (3) look up the ACGIH TLV® (or other PEL) for each, (4) take some air samples, (5) compare the sampling results to the PELs, and (6) leave and possibly file a citation.

It is usually straightforward for a site to make it difficult for OSHA industrial hygienists to measure the worst exposure values on their inspection tour. One way is to shut down some operations.