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