OSHA comments from the January 19, 1989 Final Rule on Air Contaminants Project extracted from 54FR2332 et. seq. This rule was remanded by the U.S. Circuit Court of Appeals and the limits are not currently in force.
CAS: 98-00-0; Chemical Formula: C6H6O2
OSHA’s previous limit for furfuryl alcohol was 50 ppm as an 8-hour TWA. In the NPRM, OSHA proposed revising its limit to 10 ppm as an 8-hour TWA and 15 ppm as a 15-minute STEL, and adding a skin notation, based on the ACGIH recommendation. NIOSH (Ex. 8-47, Table N1) concurred with this proposal, and these limits are established in the final rule. Furfuryl alcohol is a colorless liquid which turns red or brown on exposure to light and air.
The bases for the proposed OSHA limits, which were derived from ACGIH-recommended limits, are two foundry studies in which furfuryl alcohol was released during core preparation. Apol (1973/Ex. 1-1180) reported no discomfort among workers exposed to 10.8 ppm furfuryl alcohol, but severe lacrimation occurred at 15.8 ppm. Formaldehyde was also present at a concentration of 0.33 ppm. Burton and Rivera (1972/Ex. 1-944) found no irritation, headache, or dizziness among workers exposed to 8-hour TWA concentrations of 5 and 6 ppm, with excursions up to 16 ppm.
In its criteria document, NIOSH (1979a/Ex. 1-236) also reviewed these studies but concluded that it was unknown whether the lacrimation reported by Apol (1973/Ex. 1-1180) was caused by furfuryl alcohol, formaldehyde, or both combined. NIOSH also noted that the current OSHA limit (50 ppm) is five times lower than the concentration reported to cause no adverse effects in monkeys (Woods and Seevers 1954-1956, as cited in NIOSH 1979a/Ex. 1-236). At the time, NIOSH (1979a/Ex. 1-236) recommended that the 50-ppm limit should remain, since no information existed that showed that this limit offered inadequate protection.
Mr. H.K. Thompson, Corporate Industrial Hygiene Manager of Caterpillar, Inc. (Ex. 3-349), commented that formaldehyde probably contributed more than furfuryl alcohol to the lacrimation observed by Apol (1973/Ex. 1-1180). He also agreed that the 50-ppm PEL was too high, since his personal experience has indicated that eye irritation occurs between 25 and 30 ppm furfuryl alcohol. Mr. Thompson recommended that OSHA revise its limit to 25 ppm TWA and add a 50 ppm STEL.
In its final rule for formaldehyde, OSHA analyzed extensively the dose-response data on formaldehyde’s irritant effects. In that analysis, OSHA concluded that severe irritation and lacrimation occur in most individuals when the formaldehyde levels reach 3 ppm or above; at levels between 0.1 and 0.5 ppm, slight eye irritation may occur in some individuals (52 FR 46235). In the foundry study by Apol (1973/Ex. 1-1180), formaldehyde was present at a concentration of 0.33 ppm, about 10 times below the level associated with severe eye irritation. Therefore, OSHA believes that exposure to furfuryl alcohol levels of about 16 ppm was most likely the cause of the lacrimation reported by Apol (1973/Ex. 1-1180).
NIOSH (Ex. 150, Comments on Furfuryl Alcohol) concurred with OSHA’s proposal to revise the limits for this substance to 10-ppm TWA and 15-ppm STEL. In its posthearing submission, NIOSH cited a study by Cockcroft et al. (1980, as cited in Ex. 150), who reported that a 50-year-old moldmaker developed asthma after working with a mixture containing furfuryl alcohol, paraformaldehyde, xylene, and a catalyst containing sulfuric acid, phosphoric acid, and butyl alcohol. The patient’s bronchial response to inhaled histamines was two to three times more severe following exposure to furfuryl alcohol mixed with butyl alcohol.
OSHA finds that the additional evidence submitted by NIOSH further justifies the proposed limits. This evidence indicates that exposure to furfuryl alcohol may potentiate asthmatic responses that are suggestive of an allergic or hypersensitive condition. Individuals that are so affected frequently respond adversely to exposure levels below those that affect most other persons, and the asthmatic response is much more severe than that of respiratory tract irritation.
Therefore, OSHA concludes that the Apol (1973/Ex. 1-1180) study shows that severe eye irritation is associated with exposure to about 16 ppm furfuryl alcohol, and that furfuryl alcohol is capable of inducing more serious asthmatic responses in at least some workers. OSHA has determined that the severe eye irritation and asthma caused by exposure to furfuryl alcohol represent material impairments of health and functional capacity. The Agency is establishing PELs for this substance of 10 ppm as an 8-hour TWA and 15 ppm as a 15-minute STEL, with a skin notation, to reduce these significant risks among exposed employees. The skin notation is added to alert employers that excessive exposure may result from dermal contact; according to Proctor, Hughes, and Fischman (1988, p. 263), furfuryl alcohol is readily absorbed through the skin of animals in sufficient quantity to be lethal.