WASHINGTON, DC — Written comments will be submitted this week by the Inter-Industry Wood Dust Coordinating Committee (IWDCC) in response to the proposed lowering of the Permissible Exposure Limit (PEL) for wood dust in California. Cal/OSHA has proposed lowering the state’s wood dust permissible exposure limits from 5 mg/m³ total dust to a PEL of 1 mg/m³ inhalable dust.

Although the IWDCC’s comments to the Feasibility Advisory Committee will support the Health Expert Advisory Committee’s (HEAC) recommendation to base the PEL on “total dust” levels instead of “inhalable dust,” the IWDCC states that it does not believe “that the recommended value of 1 mg/m³ is generally feasible based on available data.”

Wood dust exposure has been a top industry concern for a number of years.

The draft comment by IWDCC references the following data sites in support of this claim: The OSHA Integrated Management Information System database which shows an exceed rate of 78%; data from the 6-year, $1.8 million Tulane Study showing that 28% of the measurements exceeded 1mg/m³ “total dust;” and the European Union database in which 41% of those exposed to “total” wood dust exceeded the proposed level.

The IWDCC draft letter concludes: “The data we have reviewed from the three large datasets clearly indicate that a 1 mg/m³ “total dust” PEL is not readily achievable. Moreover, to consistently comply with a 1 mg/m3 “total dust” PEL, one would need in practice to achieve a level of around 0.5 mg/m³. We urge the Feasibility Advisory Committee to take these data into account in its recommendation of a PEL for wood dust.”

The IWDCC is a consortium of more than 20 North American trade associations of wood source suppliers, processing operations and finished goods manufacturers. Organized by the American Forest & Paper Assn., it includes: American Home Furnishings Alliance, APA-The Engineered Wood Assn., Appalachian Hardwood Manufacturers, Architectural Woodwork Institute, Association of Woodworking& Furnishings Suppliers, Composite Panel Assn., Hardwood Manufacturers Assn., Hardwood Plywood & Veneer Assn., Kitchen Cabinet Manufacturers Assn., National Hardwood Lumber Assn., National Wooden Pallet & Container Assn., NOFMA: The Wood Flooring Manufacturers Assn., Northeastern Lumber Manufacturers Assn., Southern Forest Products Assn., Western Wood Products Assn., Wood Machinery Manufacturers of America, Wood Moulding & Millwork Producers Assn. and the Woodworking Machinery Industry Assn.