W&WP May 2003
One on One:
Despite wood dust's recent addition to the National Toxicology Program's carcinogen list, OSHA's regulatory priorities do not include a new wood dust standard.
By Greg Landgraf
Wood dust has long been a contentious health issue, with labor groups demanding tough exposure limits, industry advocating economically feasible limits that it says provide effective protection, and scientific studies debating - and frequently contradicting each other. The battle flared up again in December, as the U.S. Department of Health and Human Services National Toxicology Program officially added wood dust to its list of "known human carcinogens."
The Occupational Safety and Health Administration nominated wood dust for the carcinogen list, and while HHS publishes the Report on Carcinogens, any regulations will come through OSHA. Wood & Wood Products contacted Steven Witt, director of OSHA's Directorate of Standards & Guidance, to discuss OSHA's immediate plans for wood dust.
In the wake of wood dust's addition to the National Toxicology Program's list of known human carcinogens, does OSHA have any plans to change wood dust regulations?
There is no specific wood dust regulation for OSHA to change. However, as you probably know, wood dust is covered under OSHA's Hazard Communication Standard. Under this standard, if there is one good toxicological study that indicates an adverse health effect, employees must be informed of the hazards and associated protective measures. This is done through the provision of material safety data sheets and employee training programs. There are also provisions for container labels, but in lieu of that, given the way the material is generated in the workplace, the work areas could be placarded to provide an immediate visual warning for workers.
In terms of the carcinogenicity of wood dust, it has been required to provide information about this to workers for many years since studies have been available which indicate this type of effect. Furthermore, in 1995, the International Agency for Research on Cancer classified wood dust as a human carcinogen. The NTP listing, therefore, simply confirms the existing determination regarding carcinogenicity for purposes of hazard communication.
A 1989 standard on wood dust permissible exposure limits was overturned by an appeals court, along with standards for several hundred other substances. Have new standards for any of those substances been passed since then? How many?
Just to clarify - the court decision related to the legal process used to update OSHA's permissible exposure limits and to add additional limits already recommended by other bodies. It was not a specific determination regarding wood dust. OSHA has not been able to identify a legal process for this generic update concept that would be consistent with the court's ruling, and therefore has not taken action on the substances involved.
How high a priority is wood dust, particularly in comparison to those other substances?
OSHA's regulatory agenda establishes what the Agency's current priorities are for rulemaking during the next 12 months. The last agenda was published on December 9, 2002, and a new one is expected shortly. Wood dust does not appear on the regulatory agenda at this time, and no one at OSHA is working on a rule for wood dust. Priorities are reviewed regularly and changed as appropriate, but we do not anticipate pursuing a rule in this area in the near future.
How serious a health issue is wood dust? What are the primary health concerns, how severe are they, and how frequently do they occur because of wood dust?
Wood dust is a very serious health issue. As you know, wood dust causes cancer in humans. Many scientific studies have shown that wood dust causes cancer of the nose (nasal cavities and paranasal sinuses). In addition, wood dust may cause dermatitis, allergic respiratory effects and mucosal and non-allergic respiratory effects. The most common allergic respiratory effect is asthma. Effects on the nasal mucosa and respiratory tract that are caused by exposure to wood dust include nasal dryness, irritation, bleeding, obstruction, pneumonitis, coughing, wheezing, fever and the other signs and symptoms associated with chronic bronchitis, sneezing; sinusitis and prolonged colds.
There is a 6-year study currently being conducted by Tulane University and the Inter-Industry Wood Dust Coordinating Committee on the effect of wood dust on respiratory health. What effect could this study or others have on the regulation of wood dust?
OSHA will, of course, review any new studies or other relevant information as they become available, and will determine whether this new information suggests that we should consider changes to our priorities for regulation.
If OSHA does change the regulations on wood dust, what form would new regulations likely take? Is there any timeline on when changes might take place?
Since we are not currently contemplating adding specific wood dust regulations, it is difficult to predict the form that such new regulations would take. Were we to decide to proceed on rulemaking for wood dust, we would have to do extensive analyses of economic and technological feasibility, as well as a risk assessment and documentation of health effects, in order to determine the appropriate form of regulation.
OSHA rulemaking generally takes a number of years to complete given the extensive analyses required as well as the public rulemaking process. Anything we propose to regulate is published for submission of written comments, and there is an opportunity for oral testimony as well in public hearings. It is a considered and deliberative process to ensure the requirements are substantiated by evidence in the public record.
What advice do you have for woodworking companies in light of potential new regulations, or regarding wood dust control in general?
Engineering controls and personal protective equipment are two methods used for controlling wood dust exposure. Engineering controls, the preferred approach, typically include an exhaust ventilation system with collectors placed at points where dust is produced.
Personal protective equipment is another short-term solution to wood dust exposure. Respirators may be worn to remove hazardous particulates (dusts) and gases. The selection of appropriate respirators requires a thorough knowledge of the workplace, the potential hazardous substances and their concentration. The use of respirators also requires implementation of a respiratory protection program. And, as mentioned above, employers should ensure they are in compliance with hazard communication requirements to provide MSDSs and train their employees about the hazards of wood dusts and the protective measures in the workplace.
Is there anything you would like to add that I haven't addressed?
Yes, I'd like to point you to our very informative Web site on wood dust. There you can find much more detailed information on the subjects that we have discussed. For example, there are sawmill and woodworking "eTools" that describe the principal hazards associated with those industries and propose measures to prevent those hazards. In addition, we provide links to many other useful sources of information. You can find all this information and more at: www.osha.gov/SLTC/wooddust/index.html.
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