OSHA Standard Research Articles

The risk factors for occupational contact dermatitis among workers in a medium density fiberboard furniture factory in Eastern Thailand

The aim of this study was to determine the occupational exposure to formaldehyde on the medium-density fiberboard (MDF) dust and allergic contact dermatitis among the workers at a furniture factory. Data were collected from 439 subjects using questionnaires and patch testing to evaluate allergic contact dermatitis resulting from formaldehyde on wood dust exposure in the workplace. The geometric mean concentration of formaldehyde on MDF dust that the workers in the production department were exposed to was 2.07 ppm (GSD 4.54). Patch test results revealed that some subjects developed allergy to various substances, including epoxy resin (16.7%) and formaldehyde (5.6%). The odds ratios (95% CI) for contact dermatitis were 3.6 (1.7–7.3) among those with a history of metal allergy, 1.8 (0.6–5.2) whose family members having a history of allergic contact dermatitis. Exposure to MDF dust in the workplace should be reduced, as the current levels of exposure exceed the permissible OSHA standard.

Employer Rights and Legal Defenses to OSHA Citations

Congress placed a statutory duty on the employer and employee to be safe in the workplace, but the courts do not reciprocate this duty onto employees. 1With plant managers understandably unaware of their rights,2 and with governmental tactics to obtain consent for administrative ease,3 a company's threat to litigation may derive from its ignorance of the law. This paper aims to educate employers of their rights and counter-arguments to Secretary of Labor (Secretary) litigation as they seek independent legal counsel. An employer can deny entry of an Occupational Health and Safety Administration (OSHA) inspector lacking a warrant unless the business is in a pervasively regulated industry. The employer may ask for a copy of the warrant and the basis for the warrant and the OSHA inspector must articulate the scope and purpose of the search. An employer may request counsel to accompany the OSHA inspector during the investigation. Upon completion of the inspection, the Secretary or OSHA must issue a citation within six-months. In other words, the date of discovering a violation or when the alleged violation occurred starts the six-month statute of the limitations for a valid citation to be issued. The employer must appeal by notifying the Secretary within 15 business days after receipt of the citation. The Secretary of Labor always bears the initial burden of proving every element of an Occupational Safety and Health Act (OSH Act) violation that resulted from the employer's alleged failed compliance. An employer may raise the Multi-Employer Doctrine to argue it was an employee from another employer that created and controlled the hazard inducing incident. The employer must prove: it did not create the violative condition to which its employees were exposed; (2) it did not control the violative condition, so that it could not itself have performed the action necessary to abate the condition as required by the standard; and (3) it took all reasonable alternative measures to protect its employees from the violative condition. 4 An employer may argue that the OSH Act compliance is infeasible by demonstrating: that compliance with a particular standard either is impossible or will render performance of the work impossible; and (2) that the employer undertook alternative steps to protect its workers or that no such steps were available. 5 To rebut the presumption that the employer bears full responsibility for workplace safety, an employee's isolated and unforeseen misconduct may be held against the employee using the Unpreventable Employee Misconduct Defense. The employer shall need to prove: it established work rules or policies designed to prevent the violation;(2) it has adequately communicated these rules to its employees; (3) it has taken steps to discover violations of the work rules; and (4) it has effectively enforced these work rules when violations have been discovered.6 An employer can seek a variance proceeding that allows OSHA to preapprove the alternative safety measure before being issued a citation. However, if the alternative private-sector created safety measure appears unable to provide equivalent safety protection as the OSHA standard, then the employer risks receiving a citation after OSHA makes a final determination. The employer relinquishes the option of arguing the Greater Hazard Defense upon requesting a variance proceeding. The Greater Hazard Defense requires the employer to prove: (1) compliance with OSHA standards or guidance would result in a greater hazard to employees, which the standard was designed to prevent, than would noncompliance; (2) the employer took reasonable alternative protective measures, or there are no alternative means of employee protection; and (3) a variance was unavailable or applying for a variance would have been inappropriate.7 The employer may seek a variance or risk losing the Greater Hazard Defense. An unjustified failure to seek a variance proceeding shall preclude the Greater Hazard Defense; thus, there is no defense when the employer failed to ask for one when appropriate. If an employer can show it could not seek a variance proceeding due to a statue or procedure, then the defense may be raised. An employer should do everything it can to reduce its employees' exposure to reasonably foreseeable hazards to reduce the gravity of the citation charges, even if the OSHA standard is economically or technically infeasible.

The Introduction of a Comprehensive Logging Safety Standard in the USA – The First Eighteen Months

In the 18 months since the effective date of the US Occupational Safety and Health Administration's (OSHA) Logging Standard, 289 logging site inspections had been performed in the US by OSHA personnel. In West Virginia, 25 inspections found 170 violations ranging from incomplete first-aid kits and poor record keeping to hazardous felling areas. Four of these inspections were initiated by accidents that caused serious injury or fatality. The average proposed penalty per citation was $130.59. Approximately two-thirds of West Virginia loggers expressed misgivings about the OSHA standard. However, only 36% thought that they had a good knowledge of the OSHA logging regulations. Foresters and loggers in the US should be aware that OSHA regulations pertaining to timber harvesting operations are being enforced and, in some cases, may affect the way forests are harvested and managed.

Exposure Assessment of Formaldehyde and its Symptoms among Anatomy Laboratory Workers and Medical Students

Formaldehyde has commonly been used as an embalming agent in the anatomy laboratory besides being used during production of wood, resins and plastics. This current study involved the measurement of formaldehyde exposure level among anatomy laboratory workers and medical students in anatomy laboratory using the NIOSH 2541 method. The study determined the symptoms resulted from formaldehyde exposure using self-reported symptom questionnaire that has been modified. Mean area concentration of formaldehyde 8 h TWA in the dissection hall and specimen preparation laboratory were 0.1±0.03 and 0.17±0.04 ppm, respectively. Both of these formaldehyde concentrations were below the ceiling limit of 0.30 ppm. Statistically, there was no significant difference between the formaldehyde concentration in the dissection hall and specimen preparation laboratory. The personal exposure 15 min STEL formaldehyde concentration was 2.30±1.53 ppm and it was higher than 15 min STEL of 2 ppm. Results from the anatomy laboratory workers and medical students reported through the self-reported symptom questionnaires revealed that the most common symptoms they experienced during working hour and off working hour where eye and nose irritations, which are 71.3%, 57.5 and 4.6, 8%, respectively. In conclusion, the personal exposure 15 min STEL exceeded the US OSHA standard. Even though the formaldehyde concentration for the area was under the limit, still there were risks to develop an adverse health effect.

Hex chrome PEL guidance: An overview of the employee exposure monitoring required for compliance with the new OSHA standard

Hex chrome PEL guidance: An overview of the employee exposure monitoring required for compliance with the new OSHA standard

Evaluating Beryllium Exposure Data

We read with great interest “Chronic Beryllium Disease and Sensitization at a Beryllium Processing Facility” (Rosenman et al. 2005). We wish to offer some observations that will broaden the context in which this article is understood. I agree with the statement by Rosenman et al. (2005) that a limitation of the study is the uncertainty of the exposure estimates. In addition, many statements appear to be unsupported by the data provided. For example, the statement that “most time-weighted averages were below the [Occupational Safety and Health Administration] OSHA (2005) standard of 2 μg/m3” (Rosenman et al. 2005) is unsupported by the data in the tables. Table 11 demonstrates that > 91% of the cohort had average daily weighted average (DWA) exposures > 2 μg/m3. Table 12 presents only the highest exposures and shows 56% of the cohort members having exposures > 2 μg/m3 and all but two cohort members exposed to > 0.2 μg/m3. Rosenman et al. (2005) did not explain how the average exposures of the cohort exceed 2 μg/m3 at a rate greater than the peak exposures. This same mysterious artifact of average exposures exceeding peak exposures is also present in Tables 9 and 10. The exposure-estimating process used by these authors could have introduced an erroneous bias in the data set, which causes me to question the “Discussion” and the conclusions drawn from the data. One point, unstated by Rosenman et al. (2005), is that the DWA represented the daily exposure based on data averaged over 3 months. This is not the same as taking a single 8-hr air sample on 1 day because the 3-month averaging of the task data does not reveal the daily up and down variation in the individual task sample results. The National Institute for Occupational Safety and Health (NIOSH) has found DWAs not comparable to the lapel sampling method used by OSHA to determine compliance with its permissible exposure limit (PEL) or other 8-hr occupational exposure limits (OELs) (Donaldson and Stringer 1976). In addition, the average exposures presented by Rosenman et al. (2005) in their tables are the result of a second averaging by whole year and finally a third averaging by years of work. Such triple averaging further reduces the standard deviation in the data set, which results in a failure to identify the true high and low ranges of daily exposure. The American Industrial Hygiene Association (AIHA) exposure assessment guide (Mulhausen and Damiano 1998) cautions against ignoring air sample results that comprise the upper tail of an individual’s exposure distribution, especially when comparing it to PELs and OELs. The flame spectroscopy method of chemical analysis of beryllium used by Rosenman et al. (2005) during the data-collection period of this study had a detection limit of 0.1 μg/filter that translates to < 0.1 μg/m3 for any lower value. Therefore, Rosenman et al. (2005) cannot make any statements about exposures lower than this value. Rosenman et al.’s (2005) description of missing and estimated data, the illogical peak versus average data results, the triple averaged DWA exposure estimates, and the limit of analytical detection of the sampling method all combine to make it likely that virtually all members of the study population experienced multiple days of exposure > 2 μg/m3, and hence the study cannot sustain conclusions about the degree of risk associated with lower levels of exposure. This conclusion is supported by the observation that the rates of chronic beryllium disease (CBD) and sensitization were constant across all the categories of exposure used by Rosenman et al. (2005). Rosenman et al. (2005) made no recommendations regarding how to protect beryllium workers. We cannot change the past, but we can learn from it and change the future. There are two successful models of beryllium safety: one demonstrates effectiveness in preventing clinical CBD (Johnson et al. 2001), and one demonstrates prevention of beryllium sensitization (BeS) using the beryllium blood lymphocyte proliferation test as an index of BeS (Cummings K, unpublished data). Common to both models are a) organization and cleanliness of the workplace; b) control of the upper range of air level exposure using engineering and respiratory protection; c) control of beryllium migration from the work process to the worker, the work area, and outside the facility; d) detailed training of workers; and e) management and worker commitment to effective program implementation. In the facility studied by Rosenman et al. (2005), it is not clear that any of the above elements of a beryllium safety management plan were consistently accomplished. Although this is understandable, given prevalent scientific opinion at the time, going forward we should make every effort to effectively disseminate these demonstrated beryllium safety principles to the companies and workers using beryllium.

Alternative Metrics for Noise Exposure Among Construction Workers

Although the exposure-response relationships for noise-induced hearing loss are relatively well established, there is not complete agreement on which metrics of noise exposure best represent risk of hearing damage. In particular, while L(eq), based on a 3 dB exchange rate (ER) is used by most agencies, US OSHA's standard is based on the L(avg), which uses a 5 dB ER. In addition, peak levels of exposure, which are commonly found in some industries, including construction, are believed to increase risk above that predicted by the L(eq). This paper presents an analysis of a large database of noise exposures among construction workers, comparing several noise metrics, and their application to a cohort of construction workers. Metrics examined were the L(avg), L(eq) and L(max), expressing average levels of exposure across an exposure interval. Two novel metrics were derived from these monitored metrics, L(eq)/L(avg) and L(max)/L(eq), as measures of exposure variability and 'peakiness', respectively. A total of 730 workshifts, including data on 361 492 min of exposure to workers in nine trades were examined. Correlations between average metrics (L(eq), L(avg) and L(max)) are generally very high, while the variability metrics are poorly correlated with either average levels, or with each other, indicating that they characterize different aspects of exposure. Alternative models for estimating exposure for the cohort were considered and the use of a task-within-trade specific mean level was adopted. The task-specific estimates of exposure using the various metrics will be applied to the cohort's work history to explore the importance of these alternative metrics in estimating risk of noise-induced damage.

Inhaled Naphthalene Causes Dose Dependent Clara Cell Cytotoxicity in Mice but Not in Rats

Current OSHA standards for naphthalene exposure are set at 10 ppm (time-weighted average) with a standard threshold exposure concentration of 15 ppm. While several studies have thoroughly delineated the time course and dose response of injury by naphthalene administered ip, the pattern and severity of injury by inhalation exposure are unknown. These studies compare the regiospecific and dose-dependent cytotoxicity of naphthalene after inhalation exposure. Mice and rats were exposed for 4 h to naphthalene vapor at concentrations of 0–110 ppm. In rats, no injury was observed in the lung epithelium at exposure concentrations up to 100 ppm. Exposures as low as 2 ppm produced proximal airway injury in mice, with increased severity in a concentration-dependent fashion up to 75 ppm. Terminal airways of exposed mice exhibited little or no injury at low concentrations (1–3 ppm). Exposures of 8.5 ppm or higher were required to produce injury to Clara cells in the terminal airways. In contrast, administration of naphthalene (≤200 mg/kg ip) caused Clara cell cytotoxicity, which was limited to distal airways in mice. Higher doses (>300 mg/kg) extended the injury pattern toward the lobar bronchus. We conclude (1) the pattern of injury to naphthalene is highly dependent on the route of exposure, (2) lung injury to inhaled naphthalene is species dependent, and (3) Clara cells of mouse airways are exquisitely sensitive to inhaled naphthalene at concentrations well below the current OSHA standard for human exposure.

Evaluating OSHA's ethylene oxide standard: exposure determinants in Massachusetts hospitals.

This study sought to identify determinants of workplace exposures to ethylene oxide to assess the effect of the Occupational Safety and Health Administration's (OSHA's) 1984 ethylene oxide standard. An in-depth survey of all hospitals in Massachusetts that used ethylene oxide from 1990 through 1992 (96% participation, N = 90) was conducted. Three types of exposure events were modeled with logistic regression: exceeding the 8-hour action level, exceeding the 15-minute excursion limit, and worker exposures during unmeasured accidental releases. Covariates were drawn from data representing an ecologic framework including direct and indirect potential exposure determinants. After adjustment for frequencies of ethylene oxide use and exposure monitoring, a significant inverse relation was observed between exceeding the action level and the use of combined sterilizer-aerators, an engineering control technology developed after the passage of the OSHA standard. Conversely, the use of positive-pressure sterilizers that employ ethylene oxide gas mixtures was strongly related to both exceeding the excursion limit and the occurrence of accidental releases. These findings provide evidence of a positive effect of OSHA's ethylene oxide standard and specific targets for future prevention and control efforts.

Prevention of lead poisoning in construction workers: a new public health approach.

In 1990, Yale University, the Connecticut Departments of Health Services and of Transportation, the Connecticut Construction Industries Association, and the state's construction trade unions created the Connecticut Road Industry Surveillance Project (CRISP). Data from 90 bridge projects from 1991 to 1995 and approximately 2,000 workers were evaluated. The distribution of peak lead concentrations in the blood for CRISP workers classified into five groups were compared to that from workers outside of Connecticut. This demonstration project was instrumental in lowering bridge worker blood lead levels. After 1992, only the painting contract employees experienced peak blood lead levels with < or = 2% exceeding 50 microg/dl. Compared to similar workers in other states, Connecticut workers had significantly lower peak blood lead levels. Two thousand workers and over 120 contractors benefited directly from CRISP. Two key features of the CRISP model differed from the 1993 OSHA standard: a contract-specified lead health protection program and a centralized system of medical monitoring. These differences may account for the improved protection observed between the CRISP and non-Connecticut cohorts.

Silica, silicosis, and lung cancer: a risk assessment.

To investigate exposure-response relationships for silica, silicosis, and lung cancer. Quantitative review of the literature identified in a computerized literature search. The risk of silicosis (ILO category 1/1 or more) following a lifetime of exposure at the current OSHA standard of 0.1 mg/m(3) is likely to be at least 5-10% and lung cancer risk is likely to be increased by 30% or more. The exposure-response relation for silicosis is nonlinear and reduction of dust exposures would have a greater than linear benefit in terms of risk reduction. Available data suggests that 30 years exposure at 0.1 mg/m(3) might lead to a lifetime silicosis risk of about 25%, whereas reduction of the exposure to 0.05 mg/m(3) might reduce the risk to under 5%. The lifetime risk of silicosis and lung cancer at an exposure level of 0.1 mg/m(3) is high. Lowering exposures to the NIOSH recommended limit if 0.05 mg/m(3) may have substantial benefit.

Silica, silicosis, and lung cancer: a risk assessment

To investigate exposure-response relationships for silica, silicosis, and lung cancer.Quantitative review of the literature identified in a computerized literature search.The risk of silicosis (ILO category 1/1 or more) following a lifetime of exposure at the current OSHA standard of 0.1 mg/m(3) is likely to be at least 5-10% and lung cancer risk is likely to be increased by 30% or more. The exposure-response relation for silicosis is nonlinear and reduction of dust exposures would have a greater than linear benefit in terms of risk reduction. Available data suggests that 30 years exposure at 0.1 mg/m(3) might lead to a lifetime silicosis risk of about 25%, whereas reduction of the exposure to 0.05 mg/m(3) might reduce the risk to under 5%.The lifetime risk of silicosis and lung cancer at an exposure level of 0.1 mg/m(3) is high. Lowering exposures to the NIOSH recommended limit if 0.05 mg/m(3) may have substantial benefit.

“Danger Trees” in Central Appalachian Forests of the United States: An Assessment of Their Frequency of Occurrence

Logging accident statistics and evidence provided by case studies suggest that hazardous tree conditions account for many falling-object accidents in the United States. However, despite the Occupational Safety and Health Administration’s recently released comprehensive logging standard, the definition of “safe working conditions” in the context of the natural forest environment is still unclear. The OSHA standard has attempted to describe tree conditions that it considers potentially hazardous. Several of these conditions, especially those related to the condition of root systems, are difficult to evaluate during large-scale inventories. Other conditions (e.g., broken or dead tree branches and tops) are more practically and objectively assessed. This research has shown that, in the Central Appalachian region, approximately 20 trees per acre fall into one of the following six categories: alive with broken tops, alive with intact dead tops, dead with intact tops, dead with broken tops, snags with intact tops, or snags with broken tops. Approximately two-thirds of these “danger trees” were snags. In addition, inspection of the results suggests some consistency in trees per acre in each condition class among the states included in the study.

Exposure-response analysis of risk of respiratory disease associated with occupational exposure to chrysotile asbestos.

OBJECTIVES: To evaluate alternative models and estimate risk of mortality from lung cancer and asbestosis after occupational exposure to chrysotile asbestos. METHODS: Data were used from a recent update of...

Genotoxic changes after low-level solvent and fuel exposure on aircraft maintenance personnel.

Individuals may be exposed to solvent mixtures and fuel either at work or home, through air, water and food contamination. Few studies have addressed the genotoxic effects of mixed, low-level exposure to fuel and solvent. This was an optimally designed study where each subject was sampled prior to exposure and after 15 and 30 weeks while exposed, in a repeated measures design with each subject serving as his own control. Fifty men aged between 18 and 50, working on aircraft equipment operation and maintenance at a military installation were included. Eight unexposed men were concurrently sampled. Sister-chromatid exchanges (SCE) and micronuclei (MN) frequency were measured in conjunction with air sampling and expired breath analysis for jet fuel (JP-4), 1,1,1-trichloroethane, methyl ethyl ketone, xylenes, toluene and methylene chloride. Exposure levels measured by industrial hygiene were very low (all means <6 p.p.m.), <10% of the OSHA standard. Expired breath levels were also low, <25 p.p.b. A small but statistically significant increase in the frequency of SCE occurred after 30 weeks of exposure for sheet metal workers (P = 0.003) and for painters (P = 0.05). The MN frequency in the sheet metal workers initially showed a statistically significant increase, but by 30 weeks had decreased. Cigarette smoking, alcohol and caffeine use were not associated with changes from baseline for either MN or SCE. Smokers, however, had significantly higher values of SCEs at baseline than did nonsmokers. In summary, these findings suggest that small increases in SCEs in particular, may serve as a sensitive biologic indicator of low level hydrocarbon exposure in as much as statistically significant changes occurred in the highest exposed groups but not in the low or no exposure groups. Chance occurrence or exposures to other occupational or non-occupational agents cannot be eliminated as a cause of the study findings.

A behavioral evaluation of PCE exposure in patients and dry cleaners: a possible relationship between clinical and preclinical effects.

Long-term deficits in visuospatial function and memory and disturbances in mood have been clinically identified and followed in four patients occupationally exposed to perchloroethylene (PCE). A frontal/limbic hypothesis is offered as the site of pathology. A separate study among 65 dry cleaners was conducted to provide similar evidence of impairment, suggesting a continuum between clinical and preclinical effects. Three exposure zones were identified for the counter clerks, pressers, and operators corresponding to air levels of 11.2, 23.2, and 40.8 ppm. Decrements were found for visual reproductions (14.4%), the number correct (6.7%) and the latency (10%) for pattern memory, and the number correct (3.9%) for pattern recognition. Chronic, life-long deficits appear below 50 ppm and require at least 3 years of exposure. A reexamination of the OSHA standard is recommended and shows that behavioral testing can be used as an early indicator of more serious clinical effects.

Longitudinal Pulmonary Function Losses in Vermont Granite Workers: A Reevaluation

Previous studies have suggested that excessive losses of FVC and FEV1 were occurring in Vermont granite workers despite the fact that mean quartz levels existing in the industry were below the current OSHA standard of 100 micrograms/m3. We reexamined these losses in granite workers over an 8-year period, testing the workforce biennially from 1979 to 1987. All workers, including stone shed, quarry, and office, were offered forced spirometry using a 10-L water-sealed spirometer (Collins). In the peak year of participation (1983), 887 workers out of a total of approximately 1,400 were tested. Estimates of longitudinal loss were based on 711 workers who participated in at least three of the surveys. The mean age of this group was 42.9 years, and the mean years employed was 19.3 years; 21.4 percent were non-smokers (NS), 34.2 percent were ex-smokers (ES), and 44.4 percent were current smokers (CS). Average annual losses of FVC were 0.018 (SD = 0.056) L (CS, 0.025 L; NS, 0.006 L: and ES, 0.016 L). Average annual losses of FEV1 were 0.030 (SD = 0.041) L (CS, 0.038 L; NS, 0.020 L; and ES, 0.027 L). Analysis of covariance indicated that losses were related to the initial values for FVC or FEV1, height, age, and smoking status. After adjusting for these variables, the losses of both FVC and FEV1 were not correlated with years employed in the granite industry. No significant differences existed in the loss of FVC or FEV1 in categories of workers exposed to different levels of granite dust, eg, office, quarry, and stone shed workers. The annual losses of pulmonary function were significantly smaller than those estimated previously, which were 0.070 to .080 L in FVC, and 0.050-0.070 L in FEV1. We conclude that dust levels in the Vermont granite industry, which have been in conformance with OSHA permissible exposure limits, do not accelerate pulmonary function loss.

How does your fume hood rate? New assessment of current fume hood design and operations

One way to gauge you facility's ability to comply with the OSHA standard is to determine the number of fume hoods in use and evaluate how well they work.

Biologic markers in hospital workers exposed to low levels of ethylene oxide

Operators of hospital sterilizers that use ethylene oxide were studied to determine if there was a relationship between exposure and a battery of biological markers. A total of 73 workers from nine hospitals in the United States (U.S.) and one hospital in Mexico City was evaluated for ethylene oxide exposure during four months prior to collection of peripheral blood. The frequency of hemoglobin adducts (p = 0.0006) and sister-chromatid exchanges (SCEs) (p = 0.002) increased with cumulative exposure to ethylene oxide in U.S. subjects when controlling by regression analysis for various confounding factors, including cigarette smoking. Hemoglobin adducts, but not SCEs, were also increased in Mexican subjects (p = 0.0012). Chromosomal micronuclei showed no consistent relationship with exposure. The U.S. study participants were classified by four-month cumulative exposure levels of 10 ppm-h (n = 8), greater than 0 to 32 ppm-h (n = 32) and greater than 32 ppm-h (n = 11) of ethylene oxide exposure. The group with an exposure of greater than 32 ppm-h had an increased frequency of hemoglobin adducts (p = 0.002) and SCEs (p = 0.0001) compared to the nonexposed group. The estimated mean of the 8-h time-weighted average (8-h TWA) exposure levels for the highest U.S. exposure group (greater than 32 ppm-h) was 0.16 +/- 0.007 ppm (mean +/- SD). A similar exposure-related differential was observed in the Mexican subjects for hemoglobin adducts (p = 0.04) but not for SCEs. The latter finding may have been due to longer shipping times for the specimens in the cytogenetic assays. The estimated mean of the 8-h TWA exposure levels for the highest Mexican exposure group (greater than 32 ppm-h) was 0.48 +/- 0.08 ppm. This study is the third to suggest that exposures less than the U.S. OSHA standard of 1 ppm 8-h TWA result in biochemical and biologic changes. It is not known whether these changes may be indicative of increased risk of disease; however, they do appear to reflect exposure to relatively low levels of ethylene oxide. The exact meaning of these changes is unknown.

The Economic Impact of OSHA’s Proposed Rule on Occupational Exposure to Bloodborne Pathogens

The Occupational Safety and Health Administration’s (OSHA’s) proposed standard for occupational exposure to bloodborne pathogens is expected to increase the cost of health care by an estimated $852 million, including a $195 million rise in hospital costs. The hospital estimates may be extremely low based on comparisons of the actual cost of implementing universal precautions with OSHA’s estimated institutional costs of compliance. The proposed OSHA standard is excessive and rigid when compared with the existing Centers for Disease Control’s universal precaution guidelines for health care worker protection. The high compliance to universal precautions in hospitals and the few documented cases of human immunodeficiency virus seropositive conversion among health care workers raise questions about the necessity of OSHA’s proposed standard.