We were disappointed in our NIOSH colleagues' article "Engineering Controls for Furniture Strippers to Meet the OSHA Methylene Chloride PEL" (Am. Ind. Hyg. Assoc. J. 63:326-333 ). The authors failed to make mention of two important facts that are critically important to the control of methylene chloride: (1) the chemical has been designated a Hazardous Air Pollutant (HAP) under the Clean Air Act Amendments; and (2) pollution prevention should be the recommended control. The article includes a picture of a fan attached to a stack that is venting to the ambient environment, but nowhere do the authors mention that such a design could cause the stripper to run afoul of air contaminant standards_ Indeed, the final MACT rule for halogenated solvent cleaning requires carbon adsorption controls and recommends against using local exhaust in favor of pollution prevention strategies. Despite methylene chloride's HAP status, the authors did not evaluate the cost or effectiveness of a system that included an air cleaner, a filter maintenance service, or a recycling system. Such a properly-designed system would, of course, be much more expensive than the simple LEV approach presented in the article, and should have steered the authors toward investigating alternative control strategies. There are pollution prevention alternatives for furniture strippers that reduce exposures to workers and the environment. Some strippers have moved to alternative, less toxic and less volatile substitutes and we are currently conducting research on which ones perform best. Just as industrial hygienists would not appreciate environmental control professionals reporting the solution to the problem of toxic air pollution as shutting up the doors and windows and turning off the ventilation system, neither can we engage in risk shifting.
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