
As with all comprehensive standards promulgated by OSHA, the 1978 standard included provisions for medical monitoring of workers and administrative controls as adjuncts to dust control for prevention of occupational respiratory disease from cotton dust exposure. In fact, by the early 1980's, these approaches together appear to have accounted for a substantial reduction in the prevalence of byssinosis in many U.S. cotton textile mills [Merchant 1983]. However, a NIOSH-sponsored committee remained concerned that "even at very low concentrations of cotton dust, a considerable proportion of cotton textile workers may be at risk of developing byssinosis" [ASPH 1986]. (This concern reflected an earlier NIOSH conclusion that "even at levels of 0.1 or 0.2 mg/cu m there has been a definite incidence of byssinosis" [NIOSH 1974]. The concern was recently supported by evidence suggesting that dust-related accelerated decline in cotton textile workers' lung function occurs even at the 200-µg/m3 PEL among those who smoke [Glindmeyer et al. 1991].)
The continuing (albeit much lower) risk of byssinosis, the costs of further controlling dust, and the realized and potential future costs of compensating affected workers represented ample reasons to pursue alternative preventive strategies, including substitution of cotton treated to reduce toxicity for untreated cotton in textile mills [Millar 1988].