OSHA
In the US, exposure to hazards encountered in the workplace is regulated by the Occupational Safety and Health Administration (OSHA). OSHA was established by the Occupational Safety and Health Act of 1970 “. . . to assure so far as possible every working man and woman in the Nation safe and healthful working conditions . . . “ Six and a half million employers are covered by the Act. The mission of OSHA is to save lives, prevent injuries and protect the health of America's workers. Over 100 million workers count on OSHA. The Act authorizes the Secretary of Labor to set mandatory occupational safety and health standards.

OSHA addresses dermal exposures through standards (regulations)¹

  • 1910.1000, Subpart Z (Z Tables)

  • General standards with requirements specific to dermal exposure (e.g., Haz Com)

  • Comprehensive standards (e.g., MDA)
and through Non-regulatory Programs.

1910.1000, Subpart Z (Z Tables)
The regulations issued by the Department of Labor are found in the Code of Federal Regulations (CFR) at Title 29. OSHA Standards are found at Part 1910; Subpart Z addresses “Toxic and Hazardous Substances.” For general industry, Table Z-1 was originally adopted from the 1968 TLVs of the ACGIH. As the “skin designations” are not accompanied by any regulatory language, they are considered to be informational only.

The “skin” designation has the following features:

  • An “X” in the “skin designation” column only
  • Original language (TLV documentation) refers to absorption potential only
  • Based on antiquated data (pre-1968)
  • No specific language regarding PPE
  • Informational and alert purposes only.

In addition to the Z Tables, there are general standards with requirements specific for dermal exposures:

  • Hazard Communication, Subpart Z, 1910.1200

  • General Requirements, 1910, Subpart I: Personal Protective Equipment, 1910.132

  • Hazardous waste operations and Emergency Response, 1910.120

General Standards – Hazard Communication, Subpart Z, 1910.1200

Purpose:

  • to ensure that the hazards of all chemicals are evaluated, and

  • to ensure that the information concerning their hazards is transmitted to employers and employees.

Required:

  • Hazard determination

  • Hazard communication programs, including:
         1. container labeling,
         2. material safety data sheets (MSDSs) and
         3. employee training.

Hazard determination (emphasizing dermal considerations):

  • Exposure via all potential routes assessed, including dermal;

  • Skin as potential target organ in definition of “Health Hazard.” A chemical is considered “toxic” if it has a median lethal dose (LD(50)) of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each.

  • Reference to Appendix A, which contains definitions of “Hazardous Chemical” or “Health Hazard.” These definitions include the following health effects that can be associated with dermal exposures:
         • Carcinogen
         • Corrosive
         • Irritant
         • Sensitizer
with at least one positive study for these effects.

  1. Controlling hazards
  2. Assessment and selection
  3. Assessment guidelines
  4. Selection guidelines
  5. Fitting the device
  6. Devices with adjustable features
  7. Reassessment of hazards
  8. Selection guidelines for eye and face protection
  9. Selection guidelines for head protection
10. Selection guidelines for foot protection
11. Selection guidelines for hand protection
12. Cleaning and maintenance

The “Selection of gloves for protection against chemical hazards” section of 1910.132 Appendix B offers the following guidance:

  • Determine the toxic properties of the chemical(s):
         local effects on the skin and/or
         systemic effects due to absorption;
  • For dry powders: use any "chemical resistant" glove;
  • For mixtures: use chemical with the shortest breakthrough time;
  • Able to prevent skin contamination while removing.

PPE selection guidelines are for PPE in general and address general principles of hazard evaluation.

I wanted to find out how frequently dermal exposure (or PPE requirements to limit or prevent dermal exposure) was the focus of a citation. I asked the question: For the year 2000-01, what was the frequency of citation of 1910.132, General requirements for PPE, and specifically, how frequently were individual requirements cited?

To answer this question, I looked at IMIS data Oct. 1, 2000- Sept. 30, 2001. It is useful to introduce the IMIS Database:

  • Data from Federal OSHA inspections;
  • Data from state programs (approximately 50% of states operated their own programs) may not be included (as they are omitted here);
  • Citations originally issued can be contested by employers and then reduced;
  • Useful for comparisons;
  • Not useful for actual counts

Violations of 1910.132 by Paragraph for 1 year*

*OSHA Federal Standards citations, Oct. 1, 2000- Sept. 30, 2001

As you can see, the paragraphs cited most frequently are those that require that PPE be provided, used and maintained whenever assessment of the hazards deems it necessary (application), as well as the requirements to conduct the hazard assessment and certify that such hazard assessment had been conducted.

General Standards - Hazardous Waste Operations and Emergency Response, 1910.120

In Subpart H, Hazardous Materials, General description and discussion of the levels of protection and protective gear, 1910.120 Appendix B, PPE selection requires consideration of a variety of factors:

  • identification of the hazards, or suspected hazards
  • their routes of potential exposure to employees
  • the performance of the PPE materials (and seams) in providing barrier to these hazards

PPE selection is complex due to less well-characterized and changing exposure conditions.

The steps are:

1) Hazard identification and assessment
2) PPE selection
3) reassessment

This applies to inhalation, skin absorption, ingestion, and eye or skin contact.
Aspects of wipe sampling:

  • Important component of worksite analysis/hazard assessment
  • Useful tool in assessing the effectiveness of PPE, housekeeping, and decontamination programs
  • Surfaces or skin may be sampled for contamination

Surfaces include work surfaces as well as PPE surfaces (e.g., gloves, respirators). It is worth noting that the OSHA Technical Manual directs COSHOs (compliance officers) to call the Salt Lake Technical Center before performing wipe samples from the skin due to concerns about promoting skin absorption with the use of certain solvents.

I asked the question: Is wipe sampling being used to evaluate compliance with PPE requirements, and if so, for which requirements and substances?

The following background information is necessary. 1910, Subpart I, PPE, General requirements has the following parts:

  • 1910.132 Personal Protective Equipment, General Requirements
  • 1910.133 Eye and Face Protection
  • 1910.134 Respiratory Protection

PPE Citations and Wipe Samples (partial data)

Comprehensive Standards

Comprehensive standards consider the following issues:

  • Exposure monitoring
  • Methods of compliance
  • PPE requirements
  • Employee information and training;
  • Housekeeping, hygiene
  • Medical surveillance
  • Recordkeeping

Comprehensive Standards

Note regarding the table: There is ingestion potential for all but gases.

I wanted to find out how frequently dermal exposure (or PPE) was the focus of a citation for all the substance-specific standards. I asked the question: For the year 2000-01, what was the frequency of citation of substance-specific standards, and specifically, how frequently were paragraphs cited requiring PPE?

Comprehensive Standards and PPE Citations

Notes regarding the table:
  • Reg. – Regulated area which has specific provisions for Dermal exposure
  • Hygiene facilities normally consist of change room, showers, and designated lunch rooms.
  • An asterisk (*) in the last column denotes those substances that were identified in the previous table as having potential for dermal absorption.

In addition, for 13 carcinogens, for which all exposure is to be prohibited, employers are using regulated areas and extensive PPE.

Non-regulatory programs

OSHA now has a new emphasis on guidance and non-regulatory activities:

  • Voluntary Programs (VPP)
  • Consultation/Compliance assistance
  • Hazard Information Bulletins (e.g., acrylamide)
  • Interagency activities, including the OSHA, MSHA, NIOSH, EPA (OMNE) Committee that has a focus on DCP and the Interagency Testing Committee (ITC) that is working on a dermal absorption rate data rule

Some features of the proposed dermal absorption rate rule are:

  • 80 chemicals with inadequate dermal absorption rate data² were brought to the ITC by OSHA.
  • ITC designated them for further testing.^3,4,5
  • EPA published a notice soliciting voluntary testing of the chemicals in April 1996.⁶
  • In 1999, EPA published Proposed Test Rule for In Vitro Dermal Absorption Rate Testing of Certain Chemicals of Interest to Occupational Safety and Health Administration.⁷

Future Challenges

Future challenges will include:

  • Guidance and Assistance
  • Beryllium⁸:
         – Sensitization continues to occur in workers
         – Unknown contribution of the dermal route

References:
1. OSHA website ( www.osha.gov), OSHA Dermal Exposure topic page

2. “Protocol for In Vitro Percutaneous Absorption Studies,” Bronaugh, R.L. and Collier, S.W. In Vitro Percutaneous Absorption: Principles, Fundamentals, and Applications, ed. Bronaugh, R.L. and Maibach, H.I., CRC Press, Boca Raton, FL., 1991.

3. Thirty-first report of the TSCA Interagency Testing Committee to the Administrator. (58 FR 26898, May 5, 1993).

4. Thirty-second report of the TSCA Interagency Testing Committee to the Administrator. (58 FR 38490, July 16, 1993).

5. Thirty-fifth report of the TSCA Interagency Testing Committee to the Administrator. (59 FR 67596, December 29, 1994).

6. Dermal Absorption Rate Testing of Eighty OSHA Chemicals (61 FR 14773, April 3, 1996)

7. Proposed Test Rule for In Vitro Dermal Absorption Rate Testing of
Certain Chemicals of Interest to Occupational Safety and Health
Administration (64 FR 31073, June 9, 1999)

8. Occupational Exposure to Beryllium; Request for Information. (29 FR 67:7070, Nov. 26, 2002) )