Of the workers who are currently exposed to glycol ethers, only five percent ( under either the geometric mean approach or the arithmetic mean approach) would require air supplied respirators. The highest percentages of workers who would require ASRs are found in aircraft manufacturing/ repainting and " other" metal applications. On a full time equivalent basis, only two percent ( under either approach) would require ASRs. ( See Tables VIII 8 and VIII 9.)

TABLE VIII 4 EXPOSURE REDUCTIONS FOR 2 ME AFTER APPLYING ENGINEERING CONTROLS | | |

| | Geometric mean | Arithmetic mean Industry | Current | approach | approach category | utili | _______________________ | _______________________ and job | zation | | | |

category | of eng | Baseline | Average | Baseline | Average | ineering | weighted | exposures | weighted | exposures | controls | plant | after | plant | after | ( percent) | geometric | applying | arthmatic | applying | | mean | engineering | mean | engineering | | exposure | controls | exposure | controls | | ( ppm) | ( ppm) | ( ppm) | ( ppm)

__________ | __________ | __________ | __________ | __________ | __________

Manufacture of Glycol Ethers:

Loading Tech 50 0.046 NC 0.151 0.008 Process Tech 90 0.032 NC 0.044 NC Laboratory Tech 90 0.023 NC 0.027 NC Maintenance Tech 0 0.057* NC 0.079* NC Supervisor 0 0.017 NC 0.017 NC Manufacture of Chemical Intermediates:

Loading Tech 90 0.046 NC 0.151 0.027 Process Tech 90 0.032 NC 0.044 NC [ page 15586] Laboratory Tech 90 0.023 NC 0.027 NC Maintenance Tech 0 0.057* NC 0.079* NC Formulation of Paints and Coatings:

Packer 10 1.249* 0.250 1.980* 0.396 Batchmaker 70 0.354 0.223 0.906 0.289 Laboratory Tech 70 0.215 0.019 0.215 0.025 Other Metal Applications:

Painter 90 0.218 0.212 0.275 0.242 Auto Refinishing:

Spray Painter 67 0.218 0.060 0.275 0.110 Wood Furniture Mfg:

Finisher 90 0.656** 0.485 0.830** 0.490 Formulation of Inks:

Packer 20 1.249* 0.431 1.980* 0.532 Batchmaker 80 0.354 0.223 0.906 0.289 Laboratory Tech 70 0.215 0.019 0.215 0.025 Application of Inks:

Printing Operator 63 0.035 NC 0.043 NC Semiconductor Mfg:

Technician 82 0.020 NC 0.022 NC Printed Circuit Board Manufacturing:

Manufacturing Specialist 63 0.078 0.021 0.378 0.054 Coater 63 0.134** 0.027 0.217** 0.043 NC = No change from baseline; no use of engineering controls ( although respirators may be required to meet EL)

* No data on baseline 8 hour TWA exposure to 2 ME available for this job category. Data for 2 EE were used ** No data on baseline 8 hour TWA exposure to 2 ME available for this job category. Data for 2 EEA were used Source: PEI TABLE VIII 5 EXPOSURE REDUCTIONS FOR 2 MEA AFTER APPLYING ENGINEERING CONTROLS | | |

| | Geometric mean | Arithmatic mean Industry | Current | approach | approach category | utili | _______________________ | _______________________

and job | zation | | | | category | of eng | Baseline | Average | Baseline | Average | ineering | weighted | exposures | weighted | exposures | controls | plant | after | plant | after | ( percent) | geometric | applying | arthmatic | applying | | mean | engineering | mean | engineering | | exposure | controls | exposure | controls | | ( ppm) | ( ppm) | ( ppm) | ( ppm)

__________ | __________ | __________ | __________ | __________ | __________

Formulation of paints and coatings:

Packer 10 1.370** 0.274 3.643** 0.729 Batchmaker 70 0.354* 0.223 0.906* 0.289 Laboratory Technicion 70 0.215* 0.019 0.215* 0.025 Other metal applications:

Painter 90 0.104 0.043 0.364 0.233 Auto refinishing:

Spray painter 67 0.104 0.043 0.364 0.233 Formulation of inks:

Packer 20 1.370** 0.330 3.643** 0.757 Batchmaker 80 0.354* 0.223 0.906* 0.532 Laboratory technician 70 0.215* 0.019 0.215* 0.025 Application of inks:

Printing operator 63 0.035* NC 0.043* NC Semiconductor manufacturing:

Technician 82 0.020* NC 0.022* NC Printed circuit board manufacturing:

Manufacturing specialist 63 0.078* 0.021 0.378* 0.054 Coater 63 0.134** 0.027 0.217** 0.043 NC = No change from baseline; no use of engineering controls ( although respirators may be required to meet EL)

* No monitoring data on baseline 8 hour TWA exposure to 2 MEA were available. Data for 2 ME were used ** No monitoring data on baseline 8 hour TWA exposure to 2 MEA were available. Data for 2 EEA were used Source: PEI [ page 15587]

TABLE VIII 6 EXPOSURE REDUCTIONS FOR 2 EE AFTER APPLYING ENGINEERING CONTROLS | | |

| | Geometric mean | Arithmatic mean Industry | Current | approach | approach category | utili | _______________________ | _______________________

And job | zation | | | |

category | of eng | Baseline | Average | Baseline | Average | ineering | weighted | exposures | weighted | exposures | controls | plant | after | plant | after | ( percent) | geometric | applying | arthmatic | applying | | mean | engineering | mean | engineering | | exposure | controls | exposure | controls | | ( ppm) | ( ppm) | ( ppm) | ( ppm)

__________ | __________ | __________ | __________ | __________ | __________

Manufacture of Glycol Ethers:

Loading Technician 50 0.022 NC 0.047 NC Process Technician 90 0.092 0.049 0.177 0.119 Laboratory Technician 90 0.015 NC 0.017 NC Maintenance Technician 0 0.057 NC 0.079 NC Supervisor 0 0.026 NC 0.047 NC Manufacture of Chemical Intermediates:

Loading Technician 90 0.022 NC 0.047 NC Process Technician 90 0.092 0.049 0.177 0.119 Laboratory Technician 90 0.015 NC 0.017 NC Maintenance Technician 0 0.057 NC 0.079 NC Formulation of Paints and Coatings:

Packer 10 1.249 0.250 1.980 0.396 Batchmaker 70 0.673 0.324 0.714 0.361 Laboratory Technician 70 0.107* 0.041 0.118* 0.056 Aircraft Mfg/ Repainting: Spray painter 67 3.781* 1.569 7.916* 2.160 Motor Vehicle Body Manufacturing:

Spray painter 90 0.005* NC 0.035* NC Dip painter 90 0.012* NC 0.013* NC Paint mixer 50 0.010* NC 0.227* 0.050 Other Metal Applications:

Painter 90 0.052 0.051 0.111 0.098 Auto Refinishing:

Spray Painter 67 0.052 0.048 0.111 0.080 Wood Furniture Mfg:

Finisher 90 0.656* 0.485 0.830* 0.490 Formulation of Inks:

Packer 20 1.249 0.431 1.980 0.532 Batchmaker 80 0.673 0.324 0.714 0.361 Laboratory 70 0.107* 0.041 0.118* 0.056 Technician Application of Inks:

Printing Operator 63 0.056 0.046 2.441 NC Semiconductor Mfg:

Technician 82 0.011* NC 0.048* NC Printed Circuit Board Manufacturing:

Manufact

uring Spec 63 0.017 NC 0.031 NC Coater 63 0.134* 0.027 0.217* 0.043 NC = No change from baseline; no use of engineering controls ( although respirators may be required to meet EL)

* No data on baseline 8 hour TWA exposure to 2 EE available for this job category. Data for 2 EEA were used Source: PEI TABLE VIII 7 EXPOSURE REDUCTIONS FOR 2 EEA AFTER APPLYING ENGINEERING CONTROLS | | |

| | Geometric mean | Arithmatic mean Industry | Current | approach | approach category | utili | _______________________ | _______________________

And job | zation | | | |

category | of eng | Baseline | Average | Baseline | Average | ineering | weighted | exposures | weighted | exposures | controls | plant | after | plant | after | ( percent) | geometric | applying | arthmatic | applying | | mean | engineering | mean | engineering | | exposure | controls | exposure | controls | | ( ppm) | ( ppm) | ( ppm) | ( ppm)

__________ | __________ | __________ | __________ | __________ | __________

Manufacture of Glycol Ethers:

Loading Technician 50 0.027 NC 0.043 NC Process Technician 90 0.049 NC 0.077 0.062 Laboratory Technician 90 0.023 NC 0.031 NC Maintenance Technician 0 0.058 NC 0.116 NC Supervisor 0 0.017 NC 0.017 NC Formulation of Paints and Coatings:

Packer 10 1.370 0.274 3.643 0.729 Batchmaker 70 0.870 0.450 1.072 0.581 Laboratory Technician 70 0.107 0.041 0.118 0.056 Aircraft Mfg/ Repainting:

Spray painter 67 3.781 1.569 7.916 2.160 Other Metal Applications:

Painter 90 0.072 0.063 0.397 0.210 [ page 15588]

Wood Furniture Mfg:

90 0.656 0.485 0.830 0.490 Finisher Formulation of Inks:

Packer 20 1.370 0.330 3.643 0.757 Batchmaker 80 0.870 0.450 1.072 0.581 Laboratory Technician 70 0.107 0.041 0.118 0.056 Application of Inks:

Printing Operator 63 0.038 NC 2.071 0.111 Semiconductor Manufacturing:

Technician 82 0.011 NC 0.048 NC Printed Circuit Board Manufacturing:

Manufacturing Specialist 63 0.012 NC 0.030 NC Coater 63 0.134 0.027 0.217 0.043 NC = No change from baseline; no use of engineering controls ( although respirators may be required to meet EL)

Source: PEI TABLE VIII 8 METHODS OF CONTROLLING EMPLOYEE EXPOSURES ( GEOMETRIC MEAN APPROACH)

| | | | | |

| | Estimated | | | | | | number of | | | | FTE | Estimated | workers | Estimated | Percent | Estimated | workers | total | with | number of | of | number of | in Industry | exposed | exposures | workers | total | full time | ASRs category | workers | reduced | in air | exposed | equiva | due | | to TWA by | supplied | workers | lent | to | | substi | respir | in ASRs | workers | standard | | tution or | ators | due | in ASRs | as | | engineer | due to | to | due to | percent | | ing | standard | stand | standard | of total | | controls | | ard | | workers ___________ | _________ | _________ | _________ | _______ | _________ | __________

Manufacture of Glycol Ethers 344 330 14 4% 7 2%

Manufacture of Chemical Intermedi

ates 80 80 0 0% 0 0%

Formulation of Paints and Coatings 2,745 2,637 108 4% 26 1%

Aircraft Manufact

uring/ Re

painting 1,998 1,488 510 26% 255 13%

Motor Vehicle Body Manufact

uring 736 736 0 0% 0 0%

Other Metal Applica

tions 1,464 1,243 221 15% 221 15%

Automobile Refinish

ing 26,331 25,893 438 2% 54 0%*

Wood Furniture Manufact

uring 8,140 7,384 756 9% 152 2%

Formulation of Inks 946 894 52 5% 20 2%

Application of Inks 946 946 0 0% 0 0%

Semi

conductor Manufact

uring 1,704 1,704 0 0% 0 0%

Printed Circuit Board Manufact

uring 352 306 46 13% 12 4% Total 45,786 43,641 2,145 5% 795 2%

* More than zero, but less than 0.5%

Source: PEI [ page 15589]

TABLE VIII 9 METHODS OF CONTROLLING EMPLOYEE EXPOSURES ( ARITHMETIC MEAN APPROACH)

| | | | | |

| | Estimated | | | |

| | number of | | | | FTE | Estimated | workers | Estimated | Percent | Estimated | workers | total | with | number of | of | number of | in Industry | exposed | exposures | workers | total | full time | ASRs category | workers | reduced | in air | exposed | equiva | due | | to TWA by | supplied | workers | lent | to | | substi | respir | in ASRs | workers | standard | | tution or | ators | due | in ASRs | as | | engineer | due to | to | due to | percent | | ing | standard | stand | standard | of total | | controls | | ard | | workers ___________ | _________ | _________ | _________ | _______ | _________ | __________

Manufacture of Glycol Ethers 344 315 29 8% 10 3%

Manufacture Of Chemical Interme

Diates 80 68 12 15% 3 4%

Formulation of Paints And Coatings 2,745 2,637 108 4% 26 1%

Aircraft Manufact

uring/ Re

Painting 1,998 1,488 510 26% 255 13%

Motor Vehicle Body Manufact

Uring 736 736 0 0% 0 0%

Other Metal Applica

Tions 1,464 1,216 248 17% 248 17%

Automobile Refinishing 26,331 25,600 731 3% 91 0%*

Wood Furniture Manufact

Uring 8,140 7,384 756 9% 152 2%

Formulation of Inks 946 894 52 5% 20 2%

Application of Inks 946 930 16 2% 5 1% Semiconductor Manufact

Uring 1,704 1,704 0 0% 0 0%

Printed Circuit Board Manufact

Uring 352 306 46 13% 12 4%

Total 45,786 43,278 2,508 5% 822 2%

* More than zero, but less than 0.5%

Source: PEI Costs Of The Proposed Regulation OSHA has preliminarily determined that the proposed standard is economically feasible. It is performance oriented. Employers may choose any combination of engineering and work practice controls, or substitution of other chemicals for glycol ethers, to reduce exposures to or below the proposed TWAs and ELs Table VIII 10 shows estimated first year costs by industry category. All substitution costs are expected to be incurred in the first year only. By substituting, establishments would avoid all other costs in the first year, as well as all costs in future years Total first year regulatory costs ( substitution and compliance) would be $ 30.7 million under the geometric mean approach or $ 30.9 million under the arithmetic mean approach Total substitution costs exceed total compliance costs, primarily because of the large amount of substitution that would occur in formulation of paints and coatings. The highest first year cost is estimated for the paints and coatings formulation category. Substitution occurs in all industry categories except the manufacturing of glycol ethers and chemical intermediates; however, substitution costs occur in only four categories: formulation of paints and coatings, formulation of inks, semiconductor manufacturing, and printed circuit board manufacturing TABLE VIII 10 FIRST YEAR COSTS OF PROPOSED STANDARD, BY INDUSTRY CATEGORY | |

| Geometric mean approach | Arthmatic mean approach | __________________________ | ____________________________

Industry | | | | | |

Category | Cost of | Cost of | Cost of | Cost of | Cost of | Cost of | comp | substi | regula | comp | substi | regulation | liance* | tution** | tion | liance* | tution** | ($ 000)

| ($ 000) | ($ 000) | ($ 000) | ($ 000) | ($ 000) |

___________ | ________ | ________ | ________ | ________ | ________ | __________

Manufacture of Glycol Ethers 67 0 67 85 0 85 Manufacture Of Chemical Inter

mediates 40 0 40 47 0 47 Formulation Of Paints and Coatings 556 15,400 15,956 559 15,400 15,959 Aircraft Manufact

uring/ Re

painting 695 0 695 695 0 695 Motor Vehicle Body Manufact

uring 57 0 57 66 0 66 Other Metal Applica

tions 903 0 903 997 0 997 Automobile Refinish

ing 5,866 0 5,866 5,866 0 5,866 Wood Furniture Manufact

uring 997 0 997 997 0 997 Formulation of Inks 136 3,900 4,036 139 3,900 4,039 Application of Inks 67 0 67 103 0 103 Semiconductor Manufact

uring 525 650 1,175 525 650 1,175 Printed Circuit Board Manufact

uring 217 600 817 249 600 849 Total 10,124 20,550 30,674 10,328 20,550 30,878 * The first year costs of engineering controls are annualized; costs of workplace monitoring, medical surveillance and recordkeeping are estimated to be higher during the first year than they will be in subsequent years ** Although substitution costs are incurred in only four industry categories, substitution takes place in all industry categories except manufacture of glycol ethers and manufacture of chemical Intermediates Source: PEI Table VIII 11 shows estimated annual costs by industry category. These total $ 7.2 million ( geometric mean approach) or $ 7.4 million ( arithmetic mean approach). The highest annual cost is estimated to be for the automobile refinishing category. This is due to the large number of establishments; other industry categories have higher per establishment recurring costs Tables VIII 12 shows estimated first year and annual costs by requirement. Substitution is the most significant component of the first year costs. Engineering controls ( annualized) and exposure monitoring are the most significant components of annual costs.

TABLE VIII 11 ANNUAL COSTS OF PROPOSED STANDARD, BY INDUSTRY CATEGORY | |

| Geometric | Arithmetic | Mean Approach | Mean Approach Industry Category | _________________ | _________________

| |

| Total Cost | Total Cost | ($ 000) | ($ 000)

__________________________ | _________________ | _________________

Manufacture of Glycol Ethers 15 20 Manufacture of Chemical Intermediates 18 23 Formulation of Paints and Coatings 418 421 Aircraft Manufacturing/ Repainting 525 525 Motor Vehicle Body Manufacturing 21 21 Other Metal Applications 683 757 Automobile Refinishing 4,254 4,254 Wood Furniture Manufacturing 762 762 Formulation of Inks 106 109 Application of Inks 34 59 Semiconductor Manufacturing 244 244 Printed Circuit Board Manufacturing 125 157 Total 7,205 7,353 Source: PEI TABLE VIII 12 FIRST YEAR AND ANNUAL COSTS OF PROPOSED STANDARD, BY REQUIREMENT | |

| Geometric mean approach | Arithmetic mean approach | __________________________ | __________________________

Regulatory | | | |

requirement | First year | Annual | First year | Annual | ($ 000) | ($ 000) | ($ 000) | ($ 000)

_____________ | ____________ | _____________ | ____________ | _____________

Engineering Controls 2,611 2,611 2,642 2,642 Protective Clothing 707 707 707 707 Exposure Monitoring 3,309 1,815 3,377 1,882 Medical Surveillance 1,445 618 1,524 641 Respirator Protection 763 763 784 784 Respirator Fit Testing 20 20 20 20 Regulated Areas, Signs,

Labels 22 22 23 23 Hygiene Facilities 160 160 160 160 Information and Training 194 194 194 194 Housekeeping 37 37 37 37 Recordkeeping 857 259 860 262 Total Compliance Costs 10,124 7,205 10,328 7,353 Substitution Costs 20,550 0 20,550 0 GRAND TOTAL 30,674 7,205 30,878 7,353 Source: PEI Economic Feasibility Analysis OSHA preliminarily determines that companies in the industries involved in this rulemaking should be able to absorb the costs of compliance with the proposed standard without experiencing undue burden. In addition, OSHA also preliminarily determines that the compliance costs of this rulemaking will not threaten massive dislocation in any of the affected industries, will not threaten the competitive stability of any of the affected industries, and will not lead to undue concentration in any of the industries. see American Iron and Steel Institute v. OSHA, 939 F. 2d 975, 980 ( D. C. Cir. 1991; United Steelworkers of America v. Marshall, 647 F. 2d 1189, 1265 66 ( D. C. Cir. 1980), cert. denied, 453 U. S. 913 ( 1981). Therefore, OSHA preliminarily concludes that it is economically feasible to achieve the proposed standard by means of engineering and work practice controls and substitution PEI compared regulatory costs to financial and economic parameters to determine the impacts of a revised standard for glycol ethers on affected industries. They examined the extent to which establishments can pass costs of regulation on to their customers, absorb costs that cannot be passed on, and finance capital and up front regulatory costs. They also analyzed the impacts of regulatory requirements on competition and the differential impacts on small businesses. Information for these analyses was obtained from Dun & Bradstreet industry financial profiles and various reports issued by the Commerce Department. Industry wide impacts of first year and recurring costs of the proposed standard are shown in Tables VIII 13 and VIII 14. [ page 15591]

TABLE VIII 13 INDUSTRY WIDE IMPACTS OF FIRST YEAR* COSTS OF PROPOSED STANDARD | |

| Geometric mean approach | Arthmatic mean approach | ____________________________ | ___________________________

Industry | |

Category | First year regulatory costs | First year regulatory costs | ____________________________ | ___________________________

| | | | | |

| | As | As | | As | As | Thousands | percent | percent | Thousands | percent | percent | | Of | of | | of | of | | revenue | profit | | revenue | profit ____________ | _________ | _________ | ________ | _________ | ________ | ________

Manufacture of Glycol Ethers 67 0.04% 1.71% 85 0.05% 2.17%

Manufacture of Chemical Interme

diates 40 0.21% 8.25% 47 0.24% 9.76%

Formulation of Paints And Coatings 15,956 1.05% 16.41% 15,959 1.05% 16.42%

Aircraft Manufact

uring/ Re painting 695 0.01% 0.43% 695 0.01% 0.43% Motor Vehicle Body Manufact

uring 57 0.001% 0.02% 66 0.001% 0.02%

Other Metal Applica

tions 903 0.06% 1.07% 997 0.07% 1.18%

Automobile Refinish

ing 5,866 0.02% 0.25% 5,866 0.02% 0.25%

Wood Furniture Manufact

uring 997 0.09% 0.96% 997 0.09% 0.96%

Formulation of Inks 4,036 1.15% 27.25% 4,039 1.15% 27.28%

Application of Inks 67 0.02% 0.25% 103 0.03% 0.38%

Semiconductor Manufact

uring 1,175 0.04% 0.55% 1,175 0.04% 0.55%

Printed Circuit Board Manufact

uring 817 0.27% 2.77% 849 0.28% 2.88%

Total 30,674 0.05% 0.90% 30,878 0.05% 0.91%

* First year costs of engineering controls are annualized; costs of workplace monitoring, medical surveillance, and recordkeeping are estimated to be higher during the first year than they will be in subsequent years Source: PEI TABLE VIII 14 INDUSTRY WIDE IMPACTS OF ANNUAL COSTS OF PROPOSED STANDARD | |

| Geometric mean approach | Arithmetic mean approach | ____________________________ | ___________________________

Industry | |

category | Annual regulatory costs | Annual regulatory costs | ____________________________ | ___________________________

| | | | | |

| | As | As | | As | As | ( Thous | percent | percent | ( Thous | percent | percent | ands) | of | of | ands) | of | of | | revenue | profit | | revenue | profit ____________ | _________ | _________ | ________ | _________ | ________ | ________

Manufacture of Glycol Ethers 15 0.01% 0.38% 20 0.01% 0.51%

Manufacture of Chemical Interme

diates 18 0.09% 3.68% 23 0.12% 4.79%

Formulation of Paints And Coatings 418 0.03% 0.43% 421 0.03% 0.43%

Aircraft Manufact

uring/ Re painting 525 0.01% 0.32% 525 0.01% 0.32%

Motor Vehicle Body Manufact

uring 21 0.0004% 0.01% 21 0.0004% 0.01%

Other Metal Applications 683 0.04% 0.81% 757 0.05% 0.90%

Automobile Refinishing 4,254 0.01% 0.18% 4,254 0.01% 0.18%

Wood Furniture Manufact

uring 762 0.07% 0.73% 762 0.07% 0.73%

Formulation of Inks 106 0.03% 0.72% 109 0.03% 0.74%

Application of Inks 34 0.01% 0.13% 59 0.02% 0.22%

Semiconductor Manufact

uring 244 0.01% 0.11% 244 0.01% 0.11%

Printed Circuit Board Manufact

uring 125 0.04% 0.42% 157 0.05% 0.53%

Total 7,205 0.01% 0.21% 7,353 0.01% 0.22%

Source: PEI Substitution is not believed to place a significant burden on those firms which would be able to use that method of responding to the proposed regulation. Substituting firms would fund substitution costs in the first year of the proposed regulation; there would be no recurring substitution costs For those firms which do not choose to substitute, compliance costs should not pose a significant problem. In most cases, costs can be recovered through a price increase. Possible exceptions are automobile refinishing and wood furniture manufacturing. If complying wood office furniture makers cannot increase prices, their compliance costs would cause their net income to decline by as much as 11 percent under the proposed standard. If complying automobile repair shops and paint shops cannot increase prices, their net income could decline by as much as 13 percent under the proposed standard. In general, automobile refinishers should be able to accommodate these impacts. However, they would likely present a financial hardship for some operations with marginal profits Regulatory Flexibility Analysis The revised standards would have a greater impact on small than average sized businesses because compliance costs would not necessarily be proportional to establishment size. Thus, small establishments would have a greater incentive to substitute than would larger establishments. Because of their comparatively small size ( revenue of $ 400,000 or less), small printed circuit board manufacturers within the electronics industry could encounter difficulty financing the up front costs of substitution. However, small semiconductor operations ( also within the electronics sector) should have no trouble complying; at most, a price increase of only 0.2 percent would be needed to recover compliance costs. In the absence of a price increase, net income would decline by 2.4 percent for this industry category If small printed circuit board manufacturers cannot achieve price increases of from 0.5 to 0.8 percent to recover costs of the proposed standard, their earnings would decline by 5 to 8 percent.

[ page 15592]

IX. Environmental Impact Introduction OSHA has preliminarily determined that no significant environmental impact will result from the lower PELs and ancillary provisions being considered for the four glycol ethers  2 methoxyethanol ( 2 ME), 2 methoxyethanol acetate ( 2 MEA), 2 ethoxyethanol ( 2 EE), and 2 ethoxyethanol acetate ( 2 EEA). The principal source for this analysis is a study conducted for OSHA by PEI Associates, Inc., Technological Feasibility and Economic Impact Assessment of A Proposed Revision to the Glycol Ethers Standards, 110, OSHA Docket, Ex. 5 164 PEI determined on the basis of survey results and site visits that the following six substances ( all of them also glycol ethers) are the most frequently used substitutes for 2 ME, 2 MEA, 2 EE and 2 EEA: ethylene glycol monopropyl ether and its acetate, ethylene glycol monobutyl ether and its acetate, and propylene glycol monomethyl ether and its acetate. The potential for environmental impact resulting from these six substitutes is examined Air Emissions The major Federal air pollution regulation that affects glycol ether users or manufacturers is 40 CFR 60, New Source Performance Standards ( NSPS), which covers volatile organic compounds ( VOCs). Users or manufacturers of glycol ethers regulated under this standard are Automobile and Light Truck Surface Coating, Graphic Arts and Rotogravure Printing, Synthetic Organic Chemicals Manufacturing and Surface Coating of Large Appliances Mono, di and tri ethers of ethylene glycol and their acetates are listed as toxic chemicals under Section 313 of the Emergency Planning and Community Right to Know Act ( Title III of the Superfund Amendments and Reauthorization Act of 1986), which requires recordkeeping and reporting of emissions for all chemicals listed for facilities meeting the threshold requirements of the Act. Thus, the major substitutes for the glycol ethers would be covered by Section 313 in the same manner as are the glycol ethers For industries that use or manufacture glycol ethers and their substitutes, Federal regulations will prevent increases in emissions beyond those now permitted. Also, the glycol ethers and their major substitutes have low vapor pressures, which results in low concentrations in air exhaust streams. Thus, no incremental air environmental impact is likely to occur as a result of reductions in the workplace exposure limit Glycol ether using industries that are not subject to NSPS Federal regulations ( such as the electronics industry) use some engineering controls to control workplace air concentrations, but do not appear to use emission controls. That portion of the glycol ethers used that does nor remain with the product eventually evaporates and may enter the environment OSHA action to reduce workplace levels is projected to increase the trend to substitute other substances for glycol ethers. This substitution should reduce the quantity of glycol ethers entering the environment. The substitutes are generally less toxic than the four glycol ethers under study and are expected to have little environmental impact. Water Emissions Because of the way glycol ethers are sued, a water pollution problem does not appear likely. Neither the glycol ethers nor their substitutes are subject to pretreatment standards that regulate discharges of industrial waste or municipal sewage to publicly owned treatment works. State and local standards regarding biological oxygen demand and chemical oxygen demand should be sufficient to prevent nay increase in releases to water that might occur as a result of more stringent occupational exposure limits. Thus, no negative impact on the environment is projected X. Summary And Explanation Of The Proposed Standard OSHA believes that the proposed requirements set forth in this notice are necessary and appropriate to provide adequate protection to employees exposed to ethylene glycol ethers based on currently available information. Numerous reference works, journal articles, and other data obtained by OSHA have been taken into consideration in the development of this proposed standard Scope and Application: Paragraph ( a)

The proposed standard would apply to all occupational exposures to the ethylene glycol ethers 2 Methoxyethanol ( 2 ME), 2 Ethoxyethanol ( 2 EE), and their respective acetates 2 Methoxyethanol Acetate ( 2 MEA), and 2 Ethoxyethanol Acetate ( 2 EEA) except where the exposure occurs from 1) liquid mixtures which contain less than 1%, by volume, of the above compounds unless the employer has reason to believe that such mixtures could release vapors in quantities sufficient to result in an airborne concentration which meets or exceeds the ALs or ELs of the compounds or could present a hazard through dermal contact; and 2) solids made from or containing 2 ME, 2 MEA, 2 EE, or 2 EEA that are incapable of releasing these compounds into the workplace air at or above the ALs or above the ELs The exemption for liquids with less than 1% glycol ethers is consistent with the Hazard Communication Standard ( HCS), 29 CFR 1910.1200, paragraph ( g)( 2)( C)( 1), which does not require inclusion of a non carcinogenic chemical on a Material Safety Data Sheet ( MSDS) if it comprises less than 1% of the composition of the mixture. However while OSHA believes, in general, that liquid mixtures containing less than 1% glycol ethers may present little hazard, there may be situations where the mixture, despite its low concentration of glycol ethers, might release vapors at or above the action levels or above the excursion levels or present a hazard through dermal contact. For example a large volume of a mixture containing less than 1% of glycol ethers may be released ( e. g. spill or tank rupture) and give rise to high airborne levels of the glycol ethers by virtue of the large volume of mixture that is released. Also a work practice involving a prolonged or repeated dermal contact to a mixture containing less than 1% glycol ethers could provide enough exposure to the glycol ethers in the mixture to result in a significant dermal exposure. Thus it is proposed that if an employer has reason to believe that liquid mixtures with less than 1% glycol ethers could release glycol ethers vapors in concentrations at or above the action levels or above the excursion levels or could present a hazard through dermal contact, then that employer must comply with all provisions of the standard for glycol ethers. An employer's belief of the potential for such occurrences may be based on such things as information from a manufacturer or trade association or the employer's knowledge about chemical processes or work practices in his workplace OSHA also proposes that solids made from or containing glycol ethers that are capable of releasing those glycol ethers into the workplace air at or above the action levels or above the excursion levels are also exempt from the scope of this standard. In general glycol ethers are used as solvents in compounds which are used in the workplace. During the use of these compounds, the glycol ethers evaporate. Thus upon drying there is no glycol ether left in the [ page 15593]

dried compound which could off gas vapors to the workplace air. Since these solids would present little hazard, it is proposed that they be exempted from the scope of the standard. However if there are situations where solids containing glycol ethers could release vapors at or above the action levels or above the excursion levels, then these solids would be covered under the scope of the standard. OSHA is unaware of any such situations and requests information on the existence of such occurrences in the workplace This proposed standard covers only the four ethylene glycol ethers ( 2 ME, 2 MEA, 2 EE, and 2 EEA) referred to OSHA by EPA under section 9( a) of the TSCA. In the ANPR for these substances OSHA discussed the possibility of expanding the scope of the rulemaking to cover other glycol ethers. In that notice, OSHA stated that, based on their similarities in structure and routes of metabolism, the adverse effects of at least some of the other glycol ethers may be similar to 2 ME, 2 EE and their acetates. For these reasons OSHA stated that it might be appropriate to include other glycol ethers within the scope of a proposed standard for glycol ethers Several commentors to the ANPR ( Exs. 7 11, 7 12, 7 13, 7 14, 7 16, 7 17, 7 18, 7 20, 7 21, 7 23, 7 24 and 7 28) did not support expanding the scope of the rulemaking. In general these commentors stated that because of the differences in the toxicities between the four subject glycol ethers and longer chain glycol ethers, they did not believe that it was appropriate to promulgate a generic standard for all glycol ethers. In particular, ARCO ( Ex. 7 19) stressed the differences between ethylene glycol ethers and propylene glycol ethers. ARCO presented statements and evidence that propylene glycol ethers are metabolized by different pathways than the ethylene glycol ethers resulting in different primary metabolites of lesser toxicity. Furthermore ARCO added that the propylene glycol ethers have not been shown to induce adverse reproductive and/ or developmental effects similar to 2 ME, 2 EE and their acetates. NIOSH ( Ex. 7 22) stated that in general they would support a generic approach to rulemaking. However, in the case of other glycol ethers they stated that the data were limited and therefore they recommended one standard with two PELs, one for 2 ME/ 2 MEA and one for 2 EE/ 2 EEA. Two commentors to the ANPR, TVA and Public Citizen ( Exs. 7 15 and 7 25), did support a generic glycol ethers standard, stating that the effects may potentially be similar for other glycol ethers As discussed in Section V  Health Effects, OSHA believes that the data are limited on the toxicity for glycol ethers other than 2 ME, 2 EE and their acetates. The data which are available, indicate that toxicities, as well as the uses of other glycol ethers, may vary to such an extent that a generic standard for all glycol ethers may be inappropriate. For this reason the scope of this proposal is limited to occupational exposure to 2 ME, 2 EE and their acetates. OSHA requests comments on this approach. In particular, the Agency is interested in health effects data on other glycol ethers OSHA is also proposing that construction be included under the scope of the standard, by amending section 1910.19 to add a new paragraph ( n) for glycol ethers. OSHA's reasoning is as follows. Firstly, based on current evidence, OSHA believes that the proposed standard would have little impact on construction. However a significant source of exposure may occur in maintenance operations at facilities that manufacture, formulate or use glycol ethers or liquids containing glycol ethers. Exposure during these operations may be relatively high and it is necessary, therefore, that employees wear respirators, receive medical examinations and be protected by the other provisions of the proposed glycol ethers standard. Sometimes such facilities hire outside contractors to perform maintenance operations. The contention is sometimes made that the maintenance operations should be considered to be construction activities and not subject to general industry standards. Employees of such contractors are subject to the same levels of glycol ethers and need the same protection as other exposed employees. OSHA proposes to cover these employees under the glycol ethers standard Thus, although the impact of the standard will be limited, OSHA believes that construction should not be exempted from the standard. OSHA believes that a loophole would be opened in the enforcement of the standard if construction were exempted. The distinction between maintenance and construction activities is often an ambiguous one. The independent contractors who perform maintenance clearly need to be covered. If construction were excluded, these maintenance contractors might argue that their work is " construction" and that they are not covered by the standard. By covering construction, this ambiguity does not arise. This approach is consistent with other standards ( e. g., Ethylene Oxide, 29 CFR 1910.1047 and Benzene, 29 CFR 1910.1028). OSHA requests comments on this approach for glycol ethers. OSHA also welcomes data on the exposure and use of glycol ethers in the construction industry which may be different from those in general industry Definitions: Paragraph ( b)

Action level is defined as an airborne concentration of 0.05 ppm for 2 ME and 2 MEA and an airborne concentration of 0.25 ppm for 2 EE and 2 EEA, calculated as an 8 hour time weighted average ( TWA). For workers exposed at or above the action level, without regard to the use of respiratory protection, medical surveillance and air monitoring are required. Generally, where exposures are determined to be below the action levels of 0.05 ppm ( 2 ME, 2 MEA) and 0.25 ppm ( 2 EE, 2 EEA), no further action is required of the employer except provision of training as required by paragraph ( m) of this section and provision of appropriate personal protective equipment as required by paragraph ( h) of this section Measurements of employee exposure can vary considerably for a number of reasons including process variations, sampling and analytical methods limitations, and seasonal changes. Therefore, even if all the measurements taken on a given day fall below the 8 hour time weighted average ( TWA) permissible exposure limit, the possibility exists that on unmeasured days an employee's actual exposure may exceed the TWA. More explicitly, when measured exposure levels are over one half of the TWA, the employer cannot have a high degree of confidence that employees are not overexposed to glycol ethers during unmeasured periods of the work week. Conversely, when the measured concentrations are below the action level, the employer can have a reasonable degree of confidence that the TWA is not being exceeded on days when exposure measurements are not being performed Based on the above concept, the action level provides a means of triggering various provisions of the proposed regulation relative to the exposure levels of employees. This approach increases cost effectiveness and performance orientation of the standard while enhancing employee protection. For example, it is proposed that employers who maintain employee exposure below the action level be relieved of the obligations of further monitoring and medical surveillance of those employees. Employers are thereby encouraged to develop cost effective,

[ page 15594]

innovative approaches for reducing employee exposures below the action level in order to eliminate the expense of implementing certain provisions of the standard Employees will benefit by improved protection since their exposures will be less than one half of the TWA permissible exposure limit. In addition, employers can focus their attention on employees whose exposure levels may be significant. Those employees exposed at or above the action level will have the added protection of medical surveillance, monitoring, and other provisions of the proposed standard The use of action levels to trigger provisions of the proposed standard and the setting of the action level at one half of the TWA is consistent with other OSHA health standards, such as Asbestos ( 51 FR 22612, June 20, 1986; 29 CFR 1910.1001), Benzene ( 52 FR 34460, September 11, 1987; 29 CFR 1910.1028), and Formaldehyde ( 52 FR 46168, December 4, 1987; 29 CFR 1910.1048). This uniformity provides administrative consistency and continuity in developing and implementing compliance strategies for this and other applicable OSHA health standards at individual worksites Authorized Person means any person specifically authorized by the employer, whose duties require the person to enter a regulated area, or any person entering such an area as a designated representative of employees for the purpose of exercising the right to observe monitoring and measuring procedures under paragraph ( d) of this section, or any other person authorized by the Act or regulations issued under the Act. Examples of such people would include, but are not limited to, employees who normally work in the regulated area, union representatives, and OSHA compliance officers Emergency is defined to mean any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which may or does result in an unexpected release of a significant amount of glycol ethers. Every spill or leak does not automatically constitute an emergency situation. The exposure to employees must be high as well as unexpected. This is a performance oriented definition relying upon judgment Employee exposure is defined as that exposure to airborne or liquid glycol ethers which would occur if the employee were not using respiratory protective equipment or other personal protective equipment. This definition is consistent with OSHA's previous use of the term in other standards Ethylene Glycol Ethers for the purposes of this section, means 2 Methoxyethanol ( 2 ME) ( CAS No. 109 86 4), 2 Methoxyethanol acetate ( 2 MEA) ( CAS No. 110 49 6), 2 Ethoxyethanol ( 2 EE) ( CAS No. 110 80 5), and 2 Ethoxyethanol acetate ( 2 EEA) ( CAS No. 111 15 9). The family of ethylene glycol ethers is comprised of a large number of compounds. At the present time, however, this proposed standard will deal with only those four compounds noted above. These four chemicals are also known by a variety of chemical and trade names. Therefore, to eliminate confusion as to which compounds are being considered for regulation, they have also been identified by their CAS number. This number is assigned by the Chemical Abstract Service and, without regard to system of chemical nomenclature or trade name, is unique to a specific chemical. A detailed discussion of the chemical properties of these compounds can be found in Section IV, " Chemical Identification, Production and Use of Ethylene Glycol Ethers" of this document. Glycol Ethers is defined the same as " Ethylene glycol ethers"

above and for the purpose of the document is used interchangeably with the above term Objective Data means information demonstrating that a particular product or material containing glycol ethers or a specific process, operation, or activity involving glycol ethers cannot release glycol ethers in airborne concentrations at or above the action level or above the excursion limit or result in dermal exposure, even under worst case release conditions of foreseeable use. A more detailed discussion of " objective data" can be found in paragraph ( d), Exposure Monitoring, of this section Regulated Area means any area where airborne concentrations of glycol ethers exceed or can reasonably be expected to exceed the permissible exposure limits, either the 8 hour time weighted average ( TWA) permissible exposure limits of 0.1 ppm ( 2 ME, 2 MEA) and 0.5 ppm ( 2 EE, 2 EEA) or the 15 minute excursion limits ( EL) of 0.5 ppm ( 2 ME, 2 MEA) and 2.5 ppm ( 2 EE, 2 EEA). Regulated areas must be established anytime the airborne concentration of glycol ethers exceeds or can be expected to exceed the TWAs and/ or ELs. Their existence may be of extended duration, such as when currently feasible engineering and work practice controls are inadequate to lower airborne glycol ether concentrations below the PELs, or they may exist for only a short period of time as could be expected during a maintenance operation. Requirements specifically pertaining to regulated areas are found in paragraph ( e) of this section Permissible Exposure Limits: Paragraph ( c)

OSHA proposes, in paragraph ( c)( 1), to establish new permissible exposure limits for ethylene glycol ethers by amending the current standards found in 29 CFR 1910.1000, Table Z 1 A, which are 8 hour time weighted averages ( TWAs) of 200 ppm for 2 EE, 100 ppm for 2 EEA, and 25 ppm for both 2 ME and 2 MEA. OSHA is proposing new permissible exposure limits of 0.1 ppm for 2 ME and 2 MEA and 0.5 ppm for 2 EE and 2 EEA calculated as an 8 hour TWA. In addition, the Agency is proposing, in paragraph ( c)( 2), 15 minute excursion limits ( ELs) of 0.5 ppm ( 2 ME, 2 MEA) and 2.5 ppm ( 2 EE, 2 EEA). These limits are the airborne concentration, averaged over a 15 minute sampling period, resulting from monitoring conducted during an employee's anticipated highest level of exposure OSHA has proposed to amend the current TWAs based upon evidence that occupational exposure to ethylene glycol ethers at the current standards presents a significant risk of adverse hematologic, reproductive and developmental effects while the proposed TWAs would achieve a significant reduction in that risk. The basis for this action is discussed in the significance of risk, health effects, and feasibility sections preceding this section. Overall, however, OSHA has made the preliminary determination that the proposed TWAs reduce significant risk and are feasible In conjunction with the 8 hour TWAs, OSHA is proposing 15 minute excursion limits for these ethylene glycol ethers in paragraph ( c)( 2). The Agency feels that establishing ELs will further reduce significant risk. As discussed in the preliminary risk assessment section, the proposed TWAs of 0.1 ppm for 2 ME and 2 MEA and 0.5 ppm for 2 EE and 2 EEA were derived by dividing the NOELs from experimental studies by uncertainty factors of 100. OSHA believes that using an uncertainty factor of 100 results in a level at which workers will be less likely to experience adverse reproductive or developmental effects such as those observed in animal studies. However, it should be kept in mind that these levels ( 0.1 and 0.5 ppm) represent eight hour time weighted averages. Thus, it is possible that the levels for 2 ME/ 2 MEA and 2 EE/ 2 EEA could reach as high as 3.2 ppm or 16.0 ppm, respectively, for any 15 minute period and still meet the 8 hour [ page 15595]

TWAs of 0.1 and 0.5 ppm, provided that there are no other exposures in the 8 hour period. Under this exposure scenario, the uncertainty factor is lowered from 100 to approximately 3. This reduction in the margin of safety may be important in the case of reproductive and developmental effects where peak doses rather than cumulative doses may play an important role in the biological effects. For example, peak doses occurring at critical periods of fetal or spermatogenic development may induce adverse effects due to the sensitivity of that particular period of development. Thus, OSHA believes that it is important to reduce peak exposures to the extent possible. Implementing excursion limits five times the TWAs ( i. e., 0.5 for 2 ME/ 2 MEA and 2.5 ppm for 2 EE/ 2 EEA) will decrease the reduction in the uncertainty factors and thus provide a greater likelihood that workers will not suffer an adverse reproductive or developmental effect from exposure While OSHA is proposing 15 minute excursion limits of 5 times the respective TWAs, it should be noted that paragraph ( c)( 2)( A) prohibits an employee's exposure from exceeding the TWAs through such 15 minute exposures. Therefore, even though an employee receives his/ her exposure in short bursts, the overall exposure level cannot exceed the TWAs when the excursion limit exposures are calculated as an 8 hour time weighted average. In addition, when an employee's 15 minute excursion exposures, calculated as an 8 hour time weighted average, are at or above the action level, then all provisions of this section which are triggered at the action level must be implemented for that employee In addition to exposure by inhalation, glycol ethers are readily absorbed through the skin. As a result, both the OSHA PELs and the American Conference of Governmental Industrial Hygienists ( ACGIH) TLVs carry a " skin" notation for the four glycol ethers under consideration. Studies have shown that dermal absorption of these compounds, either alone or in conjunction with inhalation exposure, is capable of inducing adverse effects in animals and/ or humans ( Exs. 4 121, 4 139, 5 049, 5 073). The Agency, therefore, has proposed in paragraph ( c)( 3) that the employer assure that no employee is exposed to glycol ethers through dermal contact Exposure Monitoring: Paragraph ( d)

Paragraphs ( d)( 1) through ( d)( 7) of the proposed standard would impose monitoring requirements pursuant to Section 6( b)( 7) of the OSH Act ( 29 U. S. C. § 655) which mandates that any standard promulgated under section 6( b) shall, where appropriate, " provide for monitoring or measuring of employee exposure at such locations and intervals, and in such manner as may be necessary for the protection of employees." The Agency believes that the employer's knowledge of exposures existing among employees is fundamental to the provision of a healthful workplace. The purposes served by requiring initial and periodic air sampling for employee exposures to glycol ethers include: prevention of employee overexposure; determination of the extent of exposure at the worksite; identification of the sources of exposure to glycol ethers; collection of exposure data so that the employer can select the proper control methods to be used; and evaluation of the effectiveness of the selected methods. Monitoring enables employers to meet the legal obligation of the standard to ensure that their employees are not exposed to ethylene glycol ethers in excess of the prescribed levels and to notify employees of their exposure levels, as required by section 8( c)( 3) of the Act. In addition, collection of exposure monitoring data enables the examining physician to be informed of the existence and extent of potential sources of occupational diseases Exposure monitoring is critical to determining the specific levels of glycol ethers to which employees are exposed. A number of obligations are delineated by specific exposure levels above which certain provisions have to be implemented to protect the employees and achieve compliance with the standard. Medical surveillance and exposure monitoring provisions of the standard are triggered, for example, for employees exposed at or above the AL or above the EL. The remaining provisions of the standard are triggered by employee exposure above the TWA The exposure monitoring provision of paragraph ( d)( 1)( i) would require each employer who has a workplace or work operation covered by this section to accurately determine employee exposure to ethylene glycol ethers. While initial evaluation of employee exposure would require either actual monitoring of each employee or the use of objective data, subsequent determinations may be carried out through representative sampling and would not necessarily entail sampling of all exposed employees Paragraph ( d)( 1)( ii) would require that these determinations be made from samples that are taken within the employee's breathing zone ( personal samples) and which accurately reflect the employee's exposure, without regard to the use of respirators, to airborne concentrations of glycol ethers over an eight hour period. This permits the employer to ascertain compliance with the ALs and the TWAs. In addition, the employer must monitor employees over a fifteen minute period to determine whether they are in compliance with the excursion limits ( ELs) at operations where there is reason to believe that exposures may be above the ELs. Examples of situations which may present the potential for elevated short term exposures include, but are not limited to, where tanks are opened, filled, unloaded, or gauged; where containers or process equipment are opened; where glycol ethers are transferred between containers or added to mixtures in open systems; and where glycol ethers are used for cleaning or as a solvent in an uncontrollable situation as may be found, for example, in the cleaning of machinery where neither permanent nor temporary engineering or work practice controls are adequate to reduce the levels of glycol ethers to or below the ELs Paragraph ( d)( 1)( iii) would require the employer to determine TWA and EL employee exposures for each employee in each job classification, in each work area, and for each shift whenever exposure to glycol ethers exists. Except for the initial monitoring that would be required by this section, paragraph ( d)( 1)( iv) states that a representative sampling strategy may be developed which will measure sufficient exposure levels within each job classification or for each job task ( if there is task variation within a job classification which could result in different exposure levels within that job classification) for each workshift, in each work area to correctly characterize and not underestimate the exposure of any employee within each exposure group. However, exposure levels shall be determined for each employee in each job classification in each work area for each shift unless the employer can document that exposure levels for a given job classification are equivalent for different work shifts Representative exposure sampling is permitted when there are a number of employees performing the same job function in the same job classification under the same conditions. For such employees, it may be sufficient to monitor some fraction of such employees in order to obtain data that are " representative" of the remaining employees. Representative personal sampling of these employees must include that member( s) of the exposed group reasonably expected to have the [ page 15596]

highest exposure. This result can then be applied to the remaining employees of the group. In developing a representative sampling strategy, the employer must systematically examine process and workplace variables to identify which employees are to be monitored. Strategy development should include: 1) investigation of worksites where the nature of the operation or process indicates possible release of glycol ethers into the work environment to identify the sources of these emissions; 2) investigation of worksites where there have been employee complaints or symptoms indicative of possible exposure to glycol ethers; 3) analysis of exposure patterns within the worksite, including each employee's distance from the source of glycol ethers, variations in tasks among employees in the same job classification, employee mobility, air movement patterns, and differences in work habits As stated in paragraph ( d)( 1)( v), objective data [ as defined in paragraph ( b)] may also be used by the employer to document that the presence of glycol ethers in the workplace or products containing glycol ethers cannot result in the release of airborne concentrations of glycol ethers that would cause any employee to be exposed at or above the action level or above the EL under worst case release conditions of foreseeable use. If the employer can adequately demonstrate with objective data that the preceding conditions exist, then the employer is relieved of measuring employee exposure to glycol ethers A detailed discussion of " objective data" can be found in the final standard for Formaldehyde ( 52 FR 46255). Pertinent portions of that discussion are reproduced here for the sake of convenience and clarification . Employers can use data on physical properties, combined with information as to room dimensions, air exchange rates, and other pertinent data, including, for example, information on work practices, to estimate the maximum exposures that could be anticipated in the workplace. Relying on such an approach to estimate worker exposures from objective data requires the use of safety factors to account for uneven distribution of formaldehyde vapor in the air and the proximity of workers to emissions sources ( Ex. 73 176). Objective data could also include historical data on employee exposures, area monitoring conducted to determine ambient formaldehyde levels and emissions from sources of formaldehyde releases, or carefully evaluated monitoring conducted for other than a full shift or 15 minute period. . OSHA recognizes that many workplace factors must be taken into account by employers relying on objective data ( see 50 FR 50473).

In retaining the objective data requirement, OSHA does not intend that employers engage in complex modeling exercises as a substitute for employee exposure monitoring, and the Agency recognizes that, in workplaces where many complex factors must be considered to use objective data, a high degree of uncertainty will be associated with trying to assess employee exposures from objective data. In these instances, employers should conduct exposure monitoring instead of relying on objective data so that they can have confidence that they are in compliance with the standard's provisions Moreover, in workplaces where many complex factors combine to influence employee exposures to formaldehyde, employers may find it easier, more useful, and less costly to monitor rather than to try to evaluate employee exposures through generation and evaluation of objective data Briefly summarizing the above discussion, a number of workplace factors must be taken into account when relying on objective data ( e. g. temperature, humidity, ventilation rate, employee proximity to contaminant source), however, it is not the Agency's intent that employers engage in complex modeling exercises in place of employee exposure monitoring. In workplaces where a number of complex factors must be considered, the employer should conduct exposure monitoring, rather than relying upon objective data, to increase confidence that they are in compliance with the standard's provisions. Initial monitoring of workplace exposures would be required of all employers who have a place of employment covered under the scope of this standard. Paragraph ( d)( 2)( i) would require the employer to identify all employees who, without regard to respirator use, are exposed or may reasonably be anticipated to be exposed, at or above the action level or above the EL and to perform initial monitoring to accurately determine the exposure of employees so identified. The initial monitoring must be conducted within 60 days of the effective date of the final standard as set forth in paragraph ( o)( 2)( i). However, to relieve some of the monitoring burden and associated cost, paragraph ( d)( 2)( ii) of the proposal would permit an employer who has comparable and adequate workplace monitoring data gathered within 180 days prior to the effective date of the standard to rely on those data to satisfy the requirements of the initial monitoring. To meet the " comparable and adequate" intent of this provision, such monitoring data must have been gathered under conditions closely resembling those currently prevailing in the workplace, each employee must have been monitored, and the monitoring must satisfy all other requirements of this section including accuracy of the analytical method at the proposed action levels It should be noted that this provision would require initial monitoring to be performed for all employees who are potentially exposed to glycol ethers at or above the ALs or above the ELs. For the purpose of this section, representative sampling will not be an accepted method of initial monitoring. The reasoning behind this is that the permissible exposure limits for the 8 hour TWAs are being reduced to such an extent ( e. g., from 25 ppm to 0.1 ppm for 2 ME) that the Agency does not believe that the initial assessment of employee exposure can be accurately determined through representative sampling. This approach is further supported when one considers that the action levels of these compounds are even lower, 0.05 ppm ( 2 ME, 2 MEA) and 0.25 ppm ( 2 EE, 2 EEA). At these levels, minor variations in employee work practices or job tasks, workplace ventilation, compound concentration, and so forth can affect the level of employee exposure and thereby implementation of various provisions of this proposal. It is OSHA's belief, therefore, that employee exposure levels relative to the TWAs, ELs, and ALs can be accurately determined only by conducting initial monitoring for each employee. The only exception to performing initial monitoring is the use of objective data as discussed in paragraph ( d)( 1)( v). In assembling objective data, however, it should be noted that the Agency would question historical data used to substantiate claims of exposure levels below the proposed action levels, since the proposed action levels are near the level of reliable quantitation of the 1985 OSHA analytical method for these substances ( the proposed action level for 2 ME is actually below the level of quantitation or LOQ of the 1985 methodology). The level of quantitation ( LOQ)/ level of detection ( LOD) discussion in the 1985 analytical method states: ( Ex. 5 005)

The reliable quantitation limits and detection limits reported in the method are based upon optimization of the instrument for the smallest possible amounts of analytes. When target concentration of an analyte is exceptionally higher than these limits, they may not be attainable at the routine operating parameters.

Since the previous permissible exposure limits range from 25 ppm ( 2 ME/ 2 MEA) to 200 ppm ( 2 EE), it is doubtful that normal analytical procedures and apparatus would be optimized to achieve a target concentration at the [ page 15597]

method's LOD/ LOQ. Therefore, the Agency would seriously question the accuracy and reliability of historical monitoring results at such levels The outcome of the monitoring determines what subsequent action must be taken by the employer. If initial or periodic monitoring results show employee exposure to be below the action level, the employer may discontinue monitoring for that employee unless there is a change in production, equipment, process, personnel, control measures, or any other such factor which may result in new or additional exposure to glycol ethers. However, paragraph ( d)( 3)( i) stipulates that if initial monitoring reveals employee exposure to be at or above the AL or above the EL, then periodic monitoring must be initiated as discussed below and in paragraphs ( d)( 3)( ii) through ( d)( 3)( iv) of the proposed standard Periodic measurements are one of the most informative ways of detecting hazardous shifts in exposure concentrations, an indicator that engineering controls are not working properly or that good work practices are not being followed. The results of monitoring determine the monitoring frequency which must be adopted by the employer. Paragraph ( d)( 3)( ii) states that if the initial or periodic monitoring results show employee exposures at or above the AL, but at or below the TWA then the employer must repeat monitoring for these individuals at least every six months. As discussed previously, when monitoring results are above the action level, the employer can no longer be confident that employees are not being exposed over the TWA. Therefore, OSHA feels that periodic monitoring of employees exposed at or above the action level is necessary to assure employers that their employees are not overexposed If initial or periodic exposures are above the TWA then the employer must monitor every three months as would be required by paragraph ( d)( 3)( iii) of this section. Once employee exposures exceeding the TWA have been identified, the employer is obligated to implement measures directed at eliminating or minimizing those exposures. More frequent monitoring is warranted to determine the effectiveness of the measures in protecting workers Monitoring for the EL is generally to be carried out simultaneously with, and according to, the required monitoring frequencies discussed above. However, as stated in paragraph ( d)( 3)( iv), if an employee is exposed in excess of the EL, that employee shall be monitored at least every three months under conditions of highest exposure. As related previously in the discussion on excursion limits, exposure to short bursts of elevated levels of glycol ethers may play an important role in biological effects of these compounds. Therefore, protection against this type of exposure could be of equal concern compared to exposures exceeding the TWA. As a result, the same periodic monitoring frequency has been proposed for exposures in excess of either the TWAs or ELs OSHA believes these frequencies, which are similar to those required by other OSHA standards, such as Arsenic ( 43 FR 19854 May 5, 1978; 29 CFR 1910.1018) and Ethylene Oxide ( 49 FR 25734 June 22, 1984 and 53 FR 11414 April 6, 1988; 29 CFR 1910.1047), are necessary and sufficient for providing useful information to evaluate employees' exposures. Periodic re monitoring provides the employer with assurance that employees are not experiencing higher exposures that may require the use of additional controls. In addition, these measurements remind employees and employers of the continued need to protect against the hazards which could result from exposure to glycol ethers Employees are further protected because additional monitoring would be required by paragraph ( d)( 4) when there has been a change in production, equipment, raw materials, process, personnel, or work practices which may result in new or additional exposures to glycol ethers at or above the ALs or above the ELs, or whenever the employer has any other reason to suspect that a change may result in new or additional exposures at or above the ALs or above the ELs OSHA recognizes that monitoring can be a time consuming, expensive endeavor. Therefore, this proposal offers employers the incentive to minimize employees' exposures by allowing employers to discontinue monitoring for employees under certain conditions. It is hoped that such a provision will encourage employers to maintain their employees' exposures to glycol ethers below the Al and the EL, thus maximizing the protection of employees' health Paragraph ( d)( 5)( i) through ( d)( 5)( iii) would permit the employer to discontinue monitoring for an employee, except as noted otherwise in paragraph ( d)( 4) of this section, if the initial monitoring results show the employee's exposure to be below the AL and at or below the ELs. If periodic monitoring results indicate, by at least two consecutive measurements taken at least seven days apart, that employee exposures have fallen below the ALs, and are at or below the ELs, the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring. However, the results must be statistically representative and consistent with the employer's knowledge of the job and work operation. Also, paragraph ( d)( 5)( iii) states that if the initial or periodic monitoring reveals the employee to be at or above the AL but, on two consecutive measurements taken at least seven days apart, the employee is not exposed above the EL, no further monitoring for the EL is necessary except as required by paragraph ( d)( 4) of this section When considering termination of monitoring an employee's exposure level, the employer should have reasonable confidence that the employee's exposure has truly been reduced below the AL and/ or EL. Variations in job task, daily production, ventilation patterns, and so forth could result in a non characteristically low exposure measurement and, if only one sample is considered, lead the employer to incorrectly deduce that the employee is no longer overexposed. To minimize the possibility of the occurrence of such an incorrect supposition, increase the employer's confidence in terminating monitoring, and to further protect employees against overexposure, the Agency would require that, at a minimum, the employer monitor the employee's exposure level a second time, at least seven days later, to confirm the reduced exposure level before termination of monitoring. This requirement is consistent with other recent OSHA standards Paragraph ( d)( 6) would require the employer to use monitoring and analytical methods which have an accuracy ( at a confidence level of 95%) within plus or minus 25% for airborne concentrations of glycol ethers at or above the level being investigated. This is necessary to assure that 95 percent of the measurements are accurate to within plus or minus 25 percent of the " true" exposure level. OSHA has included this accuracy requirement in other toxic substance standards ( Formaldehyde, 29 CFR 1910.1048). A method of measurement is presently available to detect ethylene glycol ethers to this degree of accuracy and is described in Appendix ( E). The proposed standard, in paragraph ( d)( 7), would require that employers notify each of their employees individually of the results of personal monitoring samples. This notification is to be given within 15 days of receipt of exposure monitoring results and is to be given in writing and [ page 15598]

by posting a notice in an appropriate location accessible to affected employees. A written notice ensures that each employee is notified while posting the results ensures that employers and supervisors are aware of the results. Posting results also permits employees to compare their monitoring results with those of co workers and results obtained from other shifts If the results of the monitoring show employee exposure to be in excess of the TWA and/ or EL permissible exposure limits, the written notice to the employees shall include a statement that the TWA and/ or EL has been exceeded and a description of the corrective action which is being taken by the employer to decrease the exposure to within the permissible exposure limits. This requirement to inform employees is in accordance with section 8( c)( 3) of the OSH Act and is necessary to assure employees that the employer is making efforts to furnish them with a safe and healthful work environment As required by Section 8( c)( 3) of the Act [ 29 U. S. C. 657( c)( 3)], this proposal contains provisions for employee observation of exposure monitoring. Paragraph ( d)( 8)( i) would require employers to provide affected employees or their designated representative with the opportunity to observe any monitoring of employee exposures to glycol ethers as required by this section. In paragraph ( d)( 8)( ii), observation procedures are set forth which would require the employer to provide the observer with the personal protective clothing and equipment ( e. g. coveralls, gloves, respiratory protection, protective eyewear) that is required to be worn by the employees who are working in the area. In addition, the employer must ensure that the observer uses such clothing and equipment and complies with all other applicable safety and health procedures. This requirement ensures that the observer receives adequate protection from exposure to glycol ethers Regulated Areas: Paragraph ( e):

In paragraph ( e)( 1), the proposed standard would require the employer to establish regulated areas wherever exposures to glycol ethers exceed or can be expected to exceed the TWA and/ or EL permissible exposure limits. Such areas must be established even though no employee is routinely assigned to the area; the potential for overexposure is the determining factor The Agency feels that it is the existence of a hazard which is the basis for determining the need for protective measures rather than the type of operation being performed. Therefore, establishment of a regulated area is to be carried out not only for situations where the concentration of airborne glycol ethers must unavoidably exceed the permissible exposure limits for extended periods but also for areas where exposures are temporarily over either the TWA or EL for short periods, such as might be expected while maintenance is being performed. The establishment of regulated areas is consistent with good industrial hygiene practice as it provides an effective means of limiting excess exposure to as few employees as possible. In addition, the regulated area provision of this standard conforms with similar provisions in other OSHA health standards. It should also be noted that this requirement has additional benefits to employers in that by limiting access to these areas to only authorized persons, the employer's obligation to implement the provisions of this standard triggered by exposure above the TWAs or ELs is limited to a minimum number of employees The purpose of designating regulated areas is to ensure that employers make employees aware of the presence of glycol ethers in the workplace at levels above the permissible exposure limits, thereby helping to minimize the number of employees exposed and ensuring that employees who must enter the area are provided with training and appropriate personal protective equipment. Paragraph ( e)( 1)( i) would require that regulated areas be demarcated from the rest of the workplace in any manner that adequately establishes and alerts employees to the boundary of the regulated area while paragraph ( e)( 1)( ii) stipulates that these areas be posted at all entrances and accessways with signs meeting the requirements specified in paragraph ( m)( 1)( i) of this standard. To increase the performance orientation of the standard, no detailed requirements are specified on how regulated areas should be demarcated. However, it must be assured that the manner of demarcation chosen adequately alerts employees to the boundaries of the area. In addition, readily observable signs at all entrances and accessways serve to alert the employee not only to the existence of the regulated area but reminds them to use proper personal protective equipment and respiratory protection and to observe good personal hygiene practices, such as refraining from smoking or eating in regulated areas and washing hands and face after leaving the area The proposed standard also states, in paragraph ( e)( 2), that the employer shall limit access to regulated areas to only authorized persons. By limiting access to authorized persons only, the employer minimizes the number of persons exposed to glycol ethers. In addition, this requirement assures that only those persons who have been properly trained and utilize proper protective equipment are permitted into the area In paragraph ( e)( 3) of the proposal, it is stipulated that whenever an employer at a multiemployer worksite establishes a regulated area, that employer shall communicate the location and restrictions of access to the regulated area to other employers with work operations at that worksite. This requirement would lessen the possibility that unauthorized, unprotected people would enter the area and be inadvertently exposed. OSHA is concerned that employees at nearby sites be aware of the existence of the hazard and remain outside of the regulated area. Even though the signs posted by the first employer serve to warn employees of a second employer to stay out of the area, there is no assigned accountability for these employees. Therefore, if the second employer is aware of the hazards, then it is the responsibility of the second employer to assure that his employees do not enter the regulated area of the first employer without permission and proper protective equipment It would be required, under paragraph ( e)( 4) of the proposal, that each person entering a regulated area be provided with and required to use appropriate personal protective equipment, including respiratory protection selected in accordance with paragraph ( g)( 3). This provision is also consistent with other OSHA standards ( e. g., Asbestos, 29 CFR 1910.1001). This provision applies not only to employees working " full time" in the regulated area but to any person entering the area. This approach provides a number of benefits: 1) " walk through" by employees will be discouraged since use of appropriate personal protective equipment will be required of all persons entering the area; 2) employees whose duties require them to be in the area for a longer period of time than originally anticipated will be adequately protected since it eliminates the need for employees to estimate length of time in the regulated area and make individual decisions regarding personal protective equipment; and 3) enforcement will be simplified for the employer since the use of personal protective equipment will be uniformly required of all persons in the regulated area, regardless of the length of time they will be present in the area.

[ page 15599]

Methods of Compliance: Paragraph ( f)

Paragraph ( f)( 1) of the proposed standard would require employers to institute engineering and work practice controls, to the extent feasible, as the primary means to reduce and maintain employee exposures to glycol ethers to levels at or below the TWAs or the ELs and to eliminate dermal exposure . Paragraph ( f)( 2) also requires employers, whenever they establish that feasible engineering and work practice controls are not sufficient to lower exposures to or below the TWAs or the ELs or to eliminate foreseeable dermal exposure, to nonetheless implement such controls to reduce employee exposures to the lowest levels achievable and then to provide supplemental personal protective equipment to eliminate dermal exposure and/ or achieve the TWAs or ELs through the use of respirators that comply with the requirements of paragraph ( g) of this proposed standard Engineering controls serve to reduce employee exposure in the workplace by either removing or containing the hazard or isolating the worker from exposure. These controls include, but are not limited to, process or equipment redesign ( including substitution of glycol ethers with a less toxic chemical), installation of ventilation equipment ( localized and/ or general), process or equipment enclosure, and employee isolation. In general, engineering controls act on the source of the hazard and eliminate or reduce employee exposure without reliance on the employee taking self protective action or intervention. Once implemented, engineering controls protect the employee, subject only, to periodic replacement or preventative maintenance. Engineering controls are: reliable; provide consistent levels of protection to a large number of workers; are not dependent upon individual human performance; can be monitored continually/ inexpensively; allow for predictable performance levels; remove hazards from the workplace. Once removed, the health hazard no longer poses a threat to the employee. Engineering controls are preferred by OSHA since they remove hazards from the workplace Engineering controls can be grouped into 3 categories: ( 1) substitution, ( 2) isolation, and ( 3) ventilation, both general and localized. Quite often a combination of these controls can be applied to an industrial hygiene control problem to achieve satisfactory air quality. It may not be, and usually is not, necessary or appropriate to apply all these measures to any specific potential hazard Substitution should not be overlooked as an appropriate solution to an industrial hygiene problem. One of the best ways to keep people from being exposed to a toxic substance is to stop using it entirely. This is not always possible, but at least the following question should be asked: " Can a less toxic material be substituted in the process?" Other examples of substitution which may provide effective control of an air contaminant are changing from one type of process equipment to another, or even in some cases changing the process itself In general, a change in any process from a batch to a continuous type of operation carries with it an inherent reduction in potential hazard. This is true primarily because the frequency and duration of worker's potential contact with the process materials is reduced when the overall process approach becomes one of continuous operation. The substitution of processes can be applied on a fundamental basis. For example, substitution of airless spray for conventional spray equipment can reduce the exposure of a painter to toxic substances. Substitution of a paint dipping operation for the paint spray operation can reduce the potential hazard even further. In any of these cases the automation of the process can further reduce the potential hazard In addition to substitution, the principle of isolation should be considered. Although " isolation" is frequently envisioned as consisting of installation of a physical barrier between a hazardous operation and the workers, isolation can be provided without a physical barrier by appropriately placing the employee at greater distance from the source of the glycol ethers exposure and by controlling employees' exposures by scheduling work assignments when the fewest employees are present. Examples of this latter method would be operating a contaminant producing operation at night in the absence of most of the employees. Clean up operations in which toxic substances are involved sometimes can be performed at night in the absence of the usual production staff. Such methods of controlling worker exposures to contaminants by work assignment away from the contaminant are known as administrative controls Frequently the application of the principle of isolation maximizes the benefits of additional engineering concepts such as local exhaust ventilation. For example, the charging of mixers is the most significant operation in many processes that use formulated ingredients. When one of the ingredients in the formulation is of relatively high toxicity, it is worthwhile to isolate the mixing operation, that is, install a mixing room, thereby confining the airborne contaminants potentially generated by the operation to a small area rather than having them influence a larger area of the plant. By ensuring containment, the application of ventilation principles to control the contaminant at the source ( i. e., the mixer) is much more effective Ventilation, applied as either a general or local control, is by far the most important engineering control principle available to the industrial hygienist. Its principal application is to maintain airborne concentrations of contaminants at acceptable levels in the workplace A local exhaust system is used to carry off an air contaminant by capturing it at or near its source, before it spreads throughout the workplace. Some examples of local ventilation systems include a canopy hood over a hot process, slot ventilation around the periphery of a vat, and a laboratory hood enclosure. General ventilation, on the other hand, lets the contaminant spread throughout the workroom but dilutes it by circulating large quantities of air into and out of the workroom. A local exhaust system is generally preferred to ventilation by dilution ( general ventilation only) because it provides a cleaner and healthier work environment By comparison, work practice controls reduce the likelihood of exposure through alteration of the manner in which a task is performed such as how an employee positions himself/ herself relative to the source and/ or engineering control. While work practice controls also act on the source of the hazard, the protection they provide is based upon employer and employee behavior rather than installation of a physical device such as a ventilation system. Examples of some basic work practices include, but are not limited to, ( 1) limiting access to regulated work areas to authorized and specially trained personnel with proper personal protective equipment, ( 2) drawing tank car samples from an upwind position, and ( 3) performing glycol ether analyses, such as quality checks, within a chemical fume hood In many instances, the two control methodologies discussed above work in tandem as it is often necessary to employ work practices to insure effective operation of engineering controls. For example, if an employee inappropriately performs an operation [ page 15600]

outside of an exhaust hood then the protection afforded by the engineering control ( i. e., the exhaust hood) will be of little or no use. As can be seen, therefore, in many situations it is important not only that an engineering control be functioning properly but also that employees are aware of the work practices that are necessary to assure effectiveness of the control Primary reliance on engineering controls and work practices is consistent with good industrial hygiene practice and with the Agency's traditional adherence to a particular hierarchy of preferred controls. This hierarchy specifies that engineering controls and work practices are to be used in preference to respirators. OSHA has traditionally relied less on respirators in the hierarchy of controls because there are so many problems associated with their use. Often work is strenuous and the increased breathing resistance of the respirator reduces its acceptability to employees. Safety problems are presented by respirators since they limit vision. In some difficult and dangerous jobs, effective communication facilitates a safe, efficient operation. Voice transmission through a respirator can be difficult, annoying, and fatiguing. Movement of the jaw in speaking causes leakage thereby reducing the efficiency of the respirator and decreasing the employee's protection against glycol ethers exposures. Also, skin irritation can result from wearing a respirator in hot, humid conditions. Such irritation can cause considerable distress and disrupt work schedules. To be used effectively, respirators must be individually selected and fitted, conscientiously and properly worn, regularly maintained, and replaced as necessary. In many workplaces, these conditions are difficult, if not impossible, to satisfy. For these reasons and others, OSHA has concluded that reliance on respirators should be minimized Paragraph ( f)( 3) of the proposal would require that engineering controls be inspected and maintained or replaced on a regular schedule to ensure their effectiveness. Regularlyscheduled inspections are required to confirm that engineering controls such as protective shields have not been broken or removed; that ventilation systems are operating properly; that filters are being replaced on a sufficiently frequent interval; and that any other physical, mechanical, or replacement dependent controls are functioning as intended In consideration of glycol ethers' ability to be absorbed through the skin and thereby contribute to overall exposure, paragraph ( f)( 4) would require the employer to permit employees to leave the work area immediately or as soon as feasible to wash skin areas which have had contact with glycol ethers Whenever the TWAs and/ or ELs are exceeded or dermal exposure exists, paragraph ( f)( 5)( i) would require employers to establish and implement a written compliance program to reduce employee exposure to or below the TWAs and/ or ELs and eliminate dermal exposure. The plan should provide for this reduction to be accomplished, where feasible, through the use of engineering and work practice controls. If engineering and work practice controls cannot reduce exposures to or below the TWA and EL permissible exposure limits and eliminate dermal exposures then the plan shall include the use of whatever respiratory protection equipment is necessary to achieve compliance and all appropriate personal protective equipment necessary to eliminate contact with glycol ethers. In addition, the Agency believes that the emergency plan prescribed in paragraph ( k) is inherently a part of the overall compliance program since it addresses prevention of employee exposure in emergency situations. Therefore, paragraph ( f) ( 5) ( i) ( B) would require that the the written emergency plan be included in the compliance plan The written program requirement commits the employer to evaluating employee exposure and setting down an organized and complete plan of reducing employee exposures to permissible limits. Inclusion of personal protective equipment, including respiratory protection, in the plan assures that the appropriate protective equipment is selected, based on level and mode of exposure, and written into the plan for reference Paragraph ( f)( 5)( ii) would require that the written compliance program be reviewed and updated at least annually, or more often if necessary, to reflect significant changes in the employer's compliance status. By requiring, at a minimum, annual review of the compliance program, the Agency assures that the employer will update the program to reflect the current compliance status of the workplace. This review would require the employer to evaluate all new or altered tasks, procedures, processes, and so forth to determine whether they would result in occupational exposure and, if so, what exposure reduction methods must be implemented Paragraph ( f)( 5)( iii) states that the employer's written compliance program shall be submitted upon request for examination and copying to the Assistant Secretary, the Director, affected employees, and authorized employee representatives. Employee and employee representative access allows workers to gain an awareness of where the permissible exposure limits are exceeded, what steps the employer is taking to reduce or eliminate exposure, and the appropriate respiratory protection and personal protective equipment to use in these areas. Access to the plan by the Assistant Secretary is important for compliance enforcement. Access by the Director is required for that agency to carry out the various investigations and research it deems necessary. For example, performing health hazard evaluations of a plant, determining the current exposure patterns and control methodologies in industry use, and conducting epidemiological studies Respiratory Protection: Paragraph ( g)

Respirators serve as supplemental protection to reduce employee exposures when engineering and work practice controls are not sufficient to achieve the necessary reduction to or below the TWAs and ELs. The proposed standard, in paragraph ( g)( 1), states that where respiratory protection is required the employer shall provide, at no cost to the employee, and shall assure the proper use of respirators which comply with the requirements of this section to reduce employee exposures to or below the TWA and EL permissible exposure limits In paragraph ( g)( 1)( i) through ( g)( 1)( iv), the proposed standard would require that respiratory protection be worn ( 1) during the interval necessary to install or implement feasible engineering and work practice controls; ( 2) in work operations, such as maintenance and repair activities and during brief or intermittent operations, for which the employer has established that engineering and work practice controls are not yet feasible; ( 3) in work situations where the employer has implemented all feasible engineering and work practice controls and such controls are not sufficient to reduce exposure to or below the TWA and/ or EL permissible exposure limits; and ( 4) in emergencies.

In some circumstances ( e. g., certain maintenance and repair operations, emergencies, or during periods when engineering and work practice controls are being installed and implemented) OSHA recognizes that respirators may be essential to guarantee worker health and safety. Therefore, provision is made in paragraph ( g)( 1) for their use as [ page 15601]

primary controls in these instances where engineering and work practice controls cannot be used to achieve the TWAs or ELs. In other circumstances where engineering and work practice controls alone cannot reduce exposure levels to the TWAs or ELs, respirators may also be used for supplemental protection However, it must be kept in mind that the burden of proof of infeasibility rests with the employer in those circumstances where respiratory protection is used in lieu of engineering and work practice controls It would be required that all employees who wear respiratory protection be medically screened to determine whether any health conditions exist which could affect the employee's ability to wear a respirator. Considering the health problems which may be exacerbated with respirator use and their associated detrimental effects on an employee, the proposal states in paragraph ( g)( 2) that no employee shall be assigned tasks requiring the use of respiratory protection if, based upon his or her most recent medical examination, an examining physician determines that the employee will be unable to function normally while wearing a respirator. Common health problems which could present difficulty with respirator use include claustrophobia ( an intolerance of feeling enclosed and a subjective feeling of breathing difficulty), chronic rhinitis, nasal allergies ( necessitating frequent removal of the respirator to deal with nasal discharges), and chronic sinusitis. In addition, difficulties with use of respirators may arise in employees with respiratory or cardiac diseases. Respiratory diseases include chronic obstructive pulmonary disease, emphysema, asthma, and moderate to severe pneumoconiosis. Cardiac or cardiorespiratory diseases that may affect respirator wear include coronary thrombosis, any type of congestive heart disease, other ischemic heart diseases, and hypertension This paragraph would also require that such employees be given the opportunity to transfer to a position where no respirator use is required. That position shall be with the same employer, in the same geographical area, and with the same seniority and rate of pay the employee had just prior to such a transfer, if such a position is available. The Agency believes that this provision will minimize the reluctance of all employees, including those experiencing difficulty with respirator use, to participate in the Medical Surveillance Program for fear of losing his or her job due to the possible inability to wear a respirator Paragraph ( g)( 3) specifies the type of respirators that may be used to provide protection from exposure to glycol ethers. This proposal would permit only supplied air respirators and would prohibit the use of air purifying respirators equipped with organic vapor cartridges or canisters. The rationale behind this decision relates, in part, to the odor threshold of the glycol ethers. Generally, an employee using an air purifying respirator can detect a poor facepiece seal or sorbent cartridge breakthrough by the odor of a chemical as it finds its way into the respirator, provided the chemical possesses good warning properties. If the odor threshold of a compound exceeds the permissible exposure limit, however, the employee is deprived of such an inherent odor warning and is not aware of a respirator inadequacy until he/ she is overexposed to the compound. Consequently, an important factor in the selection of appropriate respiratory protection is the odor threshold of the chemical of concern When considering the odor threshold of a substance, one finds that reported values are widely divergent. Two major factors which influence odor detection are differences between individuals in the ability to perceive a particular odor and the methodology employed in conducting the odor threshold determination. In their " Guide to Industrial Respiratory Protection  Appendix C" ( Ex. 5 142), NIOSH states:

Amoore and Hautala ( 33) found that on average, 95% of a population will have a personal odor threshold that lies within the range from about one sixteenth to sixteen times the reported mean " odor threshold" for a substance.

In further explanation, Amoore and Hautala state: ( Ex. 5 141)

The ability of members of the population to detect a given odor is strongly influenced by the innate variability of different persons' olfactory powers, their prior experience with that odor, and by the degree of attention they accord the matter.

This statement addresses not only personal factors which influence odor detection but also raises the issue of differences in testing methodology. Examples of methodology differences include: awareness or lack of awareness of the test subject to the purpose of the test ( i. e., to detect an odor) thereby increasing his/ her attentiveness to odor detection; presentation mode of the odor samples to the test subject; purity of the test compound; vapor modality ( liquid or gaseous); and number of trials. As can be seen, lack of standard testing methodology in conjunction with individual differences in odor perception can lead to the wide variation of odor thresholds found in the literature OSHA is aware of two documents that have attempted to account for the variabilities of reported odor thresholds  Amoore and Hautala's " Odor as an Aid to Chemical Safety: Odor Thresholds Compared with Threshold Limit Values and Volatilities for 214 Industrial Chemicals in Air and Water Dilution" ( Ex. 5 141) and the American Industrial Hygiene Association's ( AIHA) " Odor Thresholds for Chemicals with Established Occupational Health Standards" ( Ex. 5 143)

Both documents calculated and utilized the geometric means of the odor thresholds reported in their respective data collections to deal with the broad range of values. In the absence of conducting new, standardized testing, the Agency believes that this is a sound approach to obtaining a single odor threshold value which can be used in evaluating warning properties of compounds Amoore and Hautala also present a method for comparing the exposure limit of a substance and its odor threshold through calculation of an " odor safety factor" ( i. e., exposure limit divided by odor threshold). The odor safety factor can then be used to classify a compound, using the scale shown in Table A, and thereby determine what percentage of attentive persons can detect the compound at the exposure limit and what percentage of distracted persons will detect a warning of the compound at the exposure limit Table A Class Odor Safety Factor Interpretation A > 550 > 90% of distracted persons perceive warning of TLV concentration in air B 26  550 50   90% of distracted persons perceive warning of TLV concentration in air C 1  26 < 50% of distracted persons perceive warning of TLV concentration in air D 0.18  1 10   50% of attentive persons can detect TLV concentration in air E < 0.18 < 10% of attentive persons can detect TLV concentration in air Utilizing this methodology and the odor thresholds calculated by Amoore and Hautala, the four glycol ethers [ page 15602]

under consideration, at the proposed TWA permissible exposure limits, yield the following classifications:

Table B Proposed Odor Odor Compound TWA ( ppm) Threshold ( ppm) Safety Factor Class 2 ME 0.1 2.3 0.04 E 2 MEA 0.1 N/ A N/ A N/ A 2 EE 0.5 2.7 0.2 D 2 EEA 0.5 0.056 8.9 C Both 2 ME and 2 EE have very low odor safety factors with resultant classifications of Class E and Class D, respectively, which means that most employees would not be able to detect breakthrough of these compounds at the proposed TWA permissible exposure limits. The highest classification, Class C, is achieved in the case of 2 EEA, in which less than 50% of distracted persons perceive a warning of 2 EEA at the proposed TWA concentration. The Agency does not find this to be adequate warning capability to permit use of air purifying respirators Table C presents the results obtained when the odor thresholds given in the AIHA document are utilized in the above methodology. One should note that the AIHA lists two odor thresholds for the four glycol ethers: 1) the detection threshold ( d) which is the lowest concentration at which a specific percentage of the test subjects, usually 50%, can detect the stimulus as different from odor free blanks and 2) the recognition threshold ( r) which is the lowest concentration at which a specific percentage of the test subjects, usually 50%, can ascribe a definite character to the odor ( Ex. 5 143). The AIHA detection threshold values are very similar to the odor threshold values presented in Amoore and Hautala's paper and give the same classification results, therefore, only odor safety factors and classifications associated with recognition threshold values appear in Table C Table C Proposed Odor Odor Compound TWA ( ppm) Threshold ( ppm) Safety Factor Class 2 ME 0.1 2.4 ( d)

4.4 ( r) 0.011 E 2 MEA 0.1 0.33 ( d)

0.64 ( r) 0.17 E 2 EE 0.5 2.7 ( d)

6.5 ( r) 0.08 E 2 EEA 0.5 0.06 ( d)

0.13 ( r) 3.8 C Performing the calculations using the recognition thresholds again results in 2 EE and 2 MEA having very low odor safety factors. The AIHA data also yields a low odor safety factor for 2 MEA ( Amoore and Hautala present no odor threshold for this substance). 2 EEA once more achieves the highest odor safety factor and classification, Class C, which, as stated previously, can be interpreted to mean that less than 50% of distracted persons will perceive a warning of the compound at the proposed TWA concentration Amoore and Hautala state that their thresholds represent the most favorable conditions for odor testing, that is, the subjects were aware of the test, were attentive, and were trying to detect an odor The studies utilized by the AIHA for determining the odor thresholds of the four glycol ethers also appear to have utilized test subjects who were aware of their objective and therefore would be concentrating on detecting and/ or recognizing an odor. OSHA does not believe that such idealized circumstances for odor detection normally occur in the workplace. An employee would be distracted by performing other tasks ( e. g., operating machinery, reviewing charts, observing production processes) and would not normally be focusing his/ her attention on detecting a minimal odor level. Even the higher recognition threshold values are likely not to be indicative of odor perception of a distracted employee in the workplace with actual odor recognition occurring at even higher concentrations Considering the preceding information, the Agency does not feel that any of the four glycol ethers display adequate warning properties at the proposed TWA permissible exposure limits to permit use of air purifying respirators. Therefore, only supplied air respiratory protection is deemed appropriate for use with these compounds The use of supplied air respiratory protection is supported by the following NIOSH comments to the ANPR: ( Ex. 7 22)

In NIOSH CIB # 39: The Glycol Ethers, with particular reference to 2 methoxyethanol and 2 ethoxyethanol, NIOSH recommended that exposure to the glycol ethers be reduced to the lowest extent feasible. Only the most protective respirators are consistent with that recommendation: self contained breathing apparatus with full facepiece operated in the pressure demand mode, or a combination respirator which includes a Type C supplied air respirator with a full facepiece operated in the pressure demand mode and an auxiliary self contained breathing apparatus operated in the pressuredemand mode.

NIOSH goes on to state that if the proposed permissible exposure limits are below the odor threshold and OSHA decides not to follow their recommendation to permit only supplied air respiratory protection, then [ page 15603]

only cartridge or canister respirators with effective end of service life indicators should be allowed. The Agency is not aware of any NIOSH/ MSHA approved cartridges or canisters with end of service life indicators for glycol ethers Following a conservative approach and allowing only supplied air respirators eliminates the question of whether employees could be unknowingly exposed as a result of the compound's actual odor threshold being above the permissible exposure limits since the employee is no longer inhaling ambient air through a sorbent cartridge. While the employer must select the appropriate respirator from the table based upon the airborne concentration of glycol ethers, the employer may always select a respirator providing greater protection ( i. e., one prescribed for higher concentrations of glycol ethers than are present in the workplace)

The respirator selection table in the proposed standard lists the type of respiratory protection which, at a minimum, must be provided and used at each airborne concentration of glycol ethers in the workplace. In no circumstance shall a respirator be used in atmospheric concentrations which exceed that respirator's assigned protection factor. The respirators selected by the employer must be approved by the Mine Safety and Health Administration ( MSHA) and by the National Institute for Occupational Safety and Health ( NIOSH) under the provisions of 30 CFR Part 11 or any future revisions. It should be noted that NIOSH is currently in the process of revising the 30 CFR Part 11 respirator testing and certification standards. When published, this revision will be listed as 42 CFR Part 84. OSHA will expect employers to base respirator selection on the most recent published standards of the aforementioned agencies In those situations in which respirator use is required, the employer shall institute a respiratory protection program in accordance with 29 CFR 1910.134 ( b), ( d), ( e), and ( f) as would be required by paragraph ( g)( 4) of this proposed standard. This general industry standard ( 29 CFR 1910.134) includes provisions for the selection, fit, use, cleaning, and maintenance of respirators. In addition, it contains requirements for a written respiratory protection program and minimum air quality standards for supplied air respiratory protection systems A drawback to respirator use is the skin irritation that can develop with some employees, particularly in hot, humid, and/ or dirty environments. The Agency recognizes that this irritation adds to the discomfort and inconvenience already experienced by employees wearing respirators and has included paragraph ( g)( 5) with the intent of minimizing skin irritation and assuring adequate employee protection This provision states that employers must permit employees to leave the work area to wash their faces and respirator facepieces as needed to prevent skin irritation from respirator use Paragraph ( g)( 6) deals with the fit testing of respirators. The employer would be required, by paragraph ( g)( 6)( i), to assure that the respirator issued to the employee exhibits the least possible facepiece leakage and that the respirator is fitted properly and will not permit the employee to inhale glycol ethers in excess of either the TWAs or ELs. Good face fit is critical in assuring proper performance of respiratory protection. When an employee inhales through a respirator which fits poorly, contaminated workplace air can enter the respirator through gaps and leaks in the seal between the face and the facepiece. Obtaining a proper respirator fit may require the fit testing of a variety of different mask sizes from several manufacturers to select the facepiece with the best fit ( least leakage around the faceseal) for each employee. This methodology will reduce inhalation leakage to a minimum Quantitative fit testing is a procedure whereby the level of penetration of a test agent of a known concentration is measured inside the facepiece of the respirator. It provides a quantitative assessment of the fit ( the fit factor). It allows the employer to continue testing different facepieces until the optimum or best fitting respirator is identified and selected for the employee. Quantitative fit testing requires the use of moderately sophisticated testing equipment and is more expensive to perform than qualitative fit testing, which may reduce its availability in some worksites. Also testing services may not be available in all parts of the country to provide quantitative fit testing services for small employers Qualitative fit testing does not provide a numerical measure of the quality of the fit but simply determines whether a respirator fits or not. Qualitative fit testing is a technique whereby a person wearing a respirator is tested to see whether a test agent with a detectable odor or taste threshold can be detected inside the respirator. If the test agent is not detected by the employee wearing the respirator, the respirator is said to fit. Qualitative fit testing is more subjective than quantitative testing because it depends on the individual's ability to detect the test agent OSHA believes that while quantitative fit testing may have some advantages, qualitative testing conducted in accordance with the protocols described in Appendix F can adequately accomplish the intent of the standard of ensuring that each employee is assigned and wears the respirator that provides a proper fit with the least possible leakage. Comments are requested on all aspects of fit testing Paragraph ( g)( 6)( ii) states that for each employee wearing a tight fitting supplied air respirator, the employer shall perform either a qualitative or quantitative fit test. Fit testing may be accomplished by testing the particular facepiece to be used ( make, model, and size), without any air supplying equipment or attachments Testing is conducted by equipping the facepiece with appropriate air purifying elements. Upon obtaining adequate fit with a particular facepiece, then that facepiece is to be used with the supplied air system ( i. e., air supplying equipment or attachments). When quantitative fit testing is performed, half mask facepieces must exhibit a fit factor of 100 and full facepieces a fit factor of 500, at a minimum. Regardless of the fit testing protocol utilized, qualitative or quantitative, respirator protection factors are to be assigned according to the respirator selection table in the proposed standard Paragraph ( g)( 6)( iii) would require the employer to perform and certify the results of the appropriate fit tests at the time of an employee's initial fitting, at least annually thereafter, when a different size or make of respirator is used, and when a change in facial structure occurs. This frequency of fit testing is necessary to assure that factors which may affect the proper fit of a respirator are detected and necessary adjustments are performed to assure the integrity of the faceseal. For example, the fit of respirators is not standardized between manufacturers. Fit testing would be required, therefore, whenever a different size or make of respirator is used. In addition, a change in an employee's facial structure can compromise a respirator's faceseal. Examples of such changes include loss of weight, cosmetic surgery, facial scarring, and the installation of dentures. Therefore, fit testing is required at least annually and when any facial changes, such as those mentioned above, occur.

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In order to assure that employees willingly participate in fit testing and that such procedures are standardized, paragraph ( g)( 6)( iv) would require that all tests be performed at a reasonable time and place and at no cost to the employee and must be conducted in accordance with Appendix F of this proposal Personal Protective Equipment: Paragraph ( h)

The underlying premise of personal protective equipment is that its use will protect against exposure during performance of a task. Paragraph ( h) of the proposal contains a number of provisions concerned with the use of personal protective equipment. In this paragraph, employers would be required to select and provide appropriate personal protective equipment in accordance with 29 CFR 1910.132 ( General Requirements) and 29 CFR 1910.133 ( Eye and Face Protection) of the General Industry Standards as often as necessary throughout the work shift to prevent employee exposure to glycol ethers. Based on good industrial hygiene practice, paragraph ( h)( 1)( i) of the proposed standard would require that selection of personal protective equipment must be based upon the type of exposure anticipated ( e. g., hand contact, splashing, spraying, inhalation), conditions of use ( i. e. suitability of the equipment to maintain its protective capabilities under the conditions in which it will be used), and the hazard to be prevented ( e. g., splashes to the face, eye irritation, dermal exposure, aerosol inhalation). This approach is performance oriented as it requires that the employer evaluate each process or task which could present a possibility of exposure and then implement the most efficient means for protecting against the exposure The employer would also be required by paragraph ( h)( 1)( ii) of the proposal to provide the appropriate personal protective equipment at no cost to the employee and assure that employees use this equipment Provision of personal protective equipment at no cost to the employee helps assure employees' acceptance of its use in exposure situations. Since it is the employer's obligation to prevent employee exposure to glycol ethers in the workplace, the responsibility to provide personal protective equipment and assure its use rightfully rests with the employer In order to prevent employees from being unwittingly exposed and to achieve adequate protection, paragraph ( h)( 1)( iii) states that personal protective equipment such as, but not limited to, coveralls, gloves, faceshields, and rubber boots, must be made of materials sufficiently impervious to glycol ethers to prevent employee exposure to these compounds. For example, information submitted in response to the ANPR included breakthrough and permeation studies of various glove materials relative to glycol ethers ( Exs. 4 017c, 7 22 attachment 17). Both the study by Union Carbide and that of Dow Chemical indicate that butyl rubber gloves provide good protection against exposure to these compounds. The proposed regulation is performance oriented, however, and does not stipulate that protective gloves or other protective equipment be made of a specific material but simply that any equipment selected be adequate to prevent employee contact with glycol ethers. In this way, the proposed standard will not interfere with any developing technology or innovative techniques that may efficiently protect employees from contact with glycol ethers Paragraph ( h)( 1)( iv) is closely related to the preceding provision in that it would require employers to provide uncontaminated personal protective equipment as often as necessary throughout the work shift to prevent employee exposure to glycol ethers Removal and storage of personal protective equipment is covered under paragraph ( h)( 2) of the proposal. Employers would be required to assure that employees remove all personal protective equipment contaminated with glycol ethers prior to leaving the work area or as soon as feasible if the potential for soak through/ breakthrough exists. This paragraph would also require that removal of contaminated personal protective equipment be done in an area which would minimize exposure of other employees to glycol ethers Paragraph ( h)( 2)( ii) states that the employer must assure that no employee takes home glycol ethers contaminated personal protective equipment. In addition, paragraph ( h)( 2)( iii) would require the employer to assure that no employee takes glycol ether contaminated equipment out of the workplace unless authorized to do so for the purposes of laundering, cleaning, maintenance, or disposal As stated previously, the intent of personal protective equipment is to protect the employee against exposure. Therefore, if a situation arises in which glycol ethers may soak through the equipment provided then the employer must assure that the employee removes the equipment as soon as possible to prevent dermal absorption. In addition, contaminated equipment is to be removed prior to leaving the work area and in an area which would minimize exposure of other employees in order to minimize migration of the contaminant away from the worksite and prevent possible exposure of additional individuals such as fellow employees and family members through airborne or dermal routes. Only authorized employees are to be permitted to take contaminated protective equipment out of the workplace and only for the purposes of laundering, cleaning, maintenance, or disposal. It should be noted that the Agency does not intend for employees to be authorized to launder and clean contaminated items at home or at a public laundromat. Therefore, these activities have been specifically prohibited. Instead, only those employees who are trained and informed as required in paragraphs ( h)( 3)( ii) and ( h)( 3)( iii) are to be authorized to remove contaminated personal protective equipment from the workplace Contaminated personal protective equipment must be stored in such a manner so as to minimize employee exposure and shall not be worn again until cleaned or laundered. Thus, the area where protective equipment dampened with glycol ethers or glycol ethercontaining compounds are stored must be sufficiently apart from areas where employees work or congregate to prevent additional exposure to employees. Re wearing of contaminated equipment is prohibited to prevent additional employee exposure and an enhanced potential for dermal absorption. Storage areas or containers with glycol ethers contaminated personal protective equipment must have either a sign or a label, respectively, as specified in paragraph ( m)( 1)( ii)

Paragraph ( h)( 3)( i) would require that each employer must clean, launder, repair, or replace, at no cost to the employee, all required personal protective equipment for each affected employee as necessary to assure its effectiveness and stipulates that the employer is responsible for disposal of these items. The requirement to repair or replace the protective equipment is necessary to insure the proper functioning of these items and, thereby, proper employee protection. Requiring that the employer be responsible for cleaning, laundering, repair, and disposal insures that contaminated equipment will be handled only by personnel who have been trained in the proper work practices for handling this equipment as specified in paragraph ( h)( 3)( ii) and ( h)( 3)( iii). Overall, this [ page 15605]

paragraph assures that contaminated equipment remains under the control of the employer. This approach permits standardized, consistent cleaning, laundering, repair, and replacement of these items thereby maximizing their effectiveness and helping to assure that they are properly disposed of at the end of their service life The employer would also be required by paragraph ( h)( 3)( ii) to assure that only trained persons remove contaminated personal protective equipment from storage for the purpose of laundering, cleaning, repair or disposal. In this way, only those employees who are aware of the hazards of glycol ethers and use proper handling work practices will contact the equipment. Whether the employer has an on site laundry/ cleaning/ repair facility or sends the equipment off site for laundering, cleaning, or repair, the employer shall inform any person who may have contact with such equipment of glycol ethers' potentially harmful effects and of procedures to safely handle the personal protective equipment as would be required by paragraph ( h)( 3)( iii)

Paragraph ( h)( 3)( iv) states that the employer shall assure that laundering, cleaning, maintenance, and disposal are performed only at facilities which are appropriate to handle glycol ethers contaminated personal protective equipment. Therefore, as stated previously, activities such as laundering contaminated personal protective equipment at a public laundromat or in an employee's home would be prohibited. This is to assure that these operations are properly performed and to prevent inadvertent exposure of unknowing individuals Paragraph ( h)( 3)( v) stipulates that when contaminated personal protective equipment is destined for disposal, it shall be placed in a sealed container which is labeled in accordance with paragraph ( m)( 1)( ii) of this section. This provision will assure that those individuals who may come in contact with the container will be protected against exposure and will be warned of the container's contents Hygiene Protection: Paragraph ( i)

A characteristic of a number of solvents, including glycol ethers, is that they can be readily absorbed through the skin. Therefore, if employees may become splashed with liquids containing glycol ethers, paragraph ( i)( 1) would require the employer to provide conveniently located quick drench showers and assure that affected employees use these facilities immediately. Quick drench showers must be able to rapidly drench the employee with a forceful flow of water in order to effectively remove the glycol ether, thereby minimizing dermal absorption. These showers must also be located in the immediate work area of an employee who could be splashed so that they may be reached quickly should an accidental splash occur, once again reducing the length of time glycol ethers remain in contact with the skin and consequently the absorption of these compounds into the body. It is particularly important to locate showers in areas where employees do not normally wear full body protective clothing yet could potentially be accidently splashed or in areas where large volume splashes could occur. Criteria for assessing quick drench showers and eyewashes can be found in consensus standards such as ANSI Z358.1 1981 and NSA Data Sheet 1 686 80. References such as these can be used to evaluate characteristics such as flowrate, accessibility, construction, testing schedules, and so forth Paragraph ( i)( 2) would require the employer to provide eye wash fountains within the immediate work area of employees whose eyes could possibly be splashed with liquids containing glycol ethers since these compounds are eye irritants. For the same reasons as above, an employee must be able to reach the fountains quickly so that the flushing can be initiated as soon as possible after an accidental eye splash. In addition, eye wash fountains should be capable of maintaining an appropriate water pressure for an appropriate length of time to remove glycol ethers from the eyes OSHA has not proposed that separate change rooms and shower facilities be provided. In addition, showering at the end of the work shift would not be required. Based upon its understanding of glycol ethers usage patterns, the Agency envisions the use of personal protective equipment as a temporary measure utilized intermittently during performance of an employee's duties and worn over the employee's regular work clothes. It is felt that prohibiting removal of this equipment in common areas will provide adequate protection from exposure for other employees. Due to the dermal absorption properties of glycol ethers, the Agency feels that requiring showering at the end of the work shift would not provide added protection since absorption would have already occurred. Minor splashes can be washed off in normal lavatory facilities while quick drench showers are available for major exposures. In both cases, other provisions of this standard require employers to assure removal of glycol ethers from the skin immediately or as soon as feasible and replacement of contaminated equipment Paragraph ( i)( 3) would prohibit eating, drinking, smoking, and application of cosmetics in areas of glycol ethers exposure. The purpose of this provision is to prevent inadvertent ingestion, inhalation, or dermal application of glycol ethers. In addition, paragraph ( i)( 4) would prohibit wearing of personal protective equipment in lunch areas to prevent migration of glycol ethers to an area where other employees may be unknowingly exposed Housekeeping: Paragraph ( j)

Paragraph ( j)( 1) would require that all surfaces ( e. g. floors, working surfaces, exterior surfaces of equipment) be kept free of glycol ethers to the extent feasible. Not only is this consistent with the intent of General Industry Standards 29 CFR 1910.141 ( a)( 3), Housekeeping, but this provision minimizes both the unnecessary spread of glycol ethers in the workplace and an increased potential for employee exposure Paragraph ( j)( 2) would require employers to conduct a program to detect leaks and spills, including visual inspections of operations involving liquids containing glycol ethers. The intent of this provision is to minimize the number of employees who could be inadvertently exposed through either dermal contact with liquid glycol ethers or elevated airborne concentrations evolving from evaporation of such liquids In addition to the above program, paragraph ( j)( 3) would require preventative maintenance of equipment that handle glycol ethers, including surveys for leaks at intervals appropriate to assure proper functioning of equipment. This provision should assist in reducing exposure resulting from leakage caused by items such as cracked joints, corroded tanks, broken gaskets, worn valve packings, malfunctioning equipment, and so forth Periodic inspection and maintenance of process equipment and control equipment such as ventilation systems is an important work practice control. In plants where total containment is used as an engineering control, the failure of process equipment or the ventilation system can seriously increase the probable occurrence of exposures. Frequently, equipment which is near failure or in disrepair will not perform normally. Regular inspections can detect abnormal conditions so that maintenance can then be performed. If equipment is routinely inspected, replaced, or repaired before failure is [ page 15606]

likely, the risk of exposure occurring will be reduced.