VI Verbal Remarks at NIOSH OEB Public Meeting

To VI HSE Committee:

The VI presented the attached verbal comments at NIOSH’s public meeting on its proposed Occupational Exposure Banding (OEB) process. The Federal Register notice and NIOSH’s draft guidance are attached as a reference. NIOSH had several good slide presentations about their proposal, and I will forward those as they become available. My quick notes from the meeting are attached. To sum up, NIOSH explained the OEB process is intended for substances that do not currently have either an OSHA permissible exposure limit (PEL) or another occupational exposure limit (OEL) established by an authoritative body. At this time, it is not NIOSH’s intention to replace already existing PELs. With that being said, a question was raised from a meeting participant that the process could be applied to replace “ancient” PELs. VI’s comments specifically display how the current PEL for vinyl chloride is effective, and that application of the OEB would produce an overly conservative OEL. NIOSH seemed to agree with VI’s statements. VI was asked to submit these comments in writing into the docket for reference, which we intend to do by the June 13, 2017 deadline. NIOSH also explained that they are in the process of revising their carcinogen policy that was issued in December, 2016, specifically to address concerns that there is no safe level of exposure to any carcinogen.

I will circulate a draft of our written submission in early June for submission by the June 13, 2017 deadline. Your comments and questions are appreciated.

Regards,

Rich

Folks,

I meant to give credit to Larry Halprin and his colleagues at Keller and Heckman for the comments and slide presentation that I just circulated. My sincere thanks for their efforts to pull these together for our industry.

Regards,

Rich