Threshold limit values, permissible exposure limits, and feasibility: The bases for exposure limits in the United States

Abstract

The development of exposure limits in the United States has always relied heavily upon the threshold limit values (TLVs) developed by the American Conference of Governmental Industrial Hygienists (ACGIH). In fact, the TLVs were adopted as official exposure limits by the Occupational Safety and Health Administration (OSHA) in 1972 and 1989. Given the continuing importance of the ACGIH limits, this paper compares the basis of the TLVs with that employed by OSHA de novo in its 12 new permissible exposure limits (PELs). Using benzene as an example, it is shown that OSHA's new PELs have been established following a rigorous assessment of the inherent risks and the feasibility of instituting the limit. The TLVs, on the other hand, have been developed by ad hoc procedures and appear to have traditionally reflected levels thought to be achievable at the time. However, this might be changing. Analysis of the historical reductions of TLVs, for 27 substances on the 1991-1992 list of intended changes, indicates smaller reductions in the past (median reduction of 2.0-2.5-fold between 1946 and 1988) compared to those currently being observed (median reduction of 7.5-fold between 1989 and 1991). Further analysis suggests a more aggressive policy of the ACGIH regarding TLVs for carcinogens but not for substances that produce effects other than cancer. Regardless of whether the basis of the TLVs has changed recently, it would take a relatively long time for the impact of any change to be felt, since the median age of the 1991-1992 TLVs is 16.5 years, and 75% of these limits are more than 10 years old. The implications of OSHA's continued reliance on the TLVs as a means of updating its PELs are discussed, and four alternatives are presented to the ACGIH regarding the future of its activities related to exposure limits. It is concluded that new mechanisms are needed for OSHA to update its PELs in a timely fashion so that the TLVs will not be adopted by default in the future.