Re: OSHA levels for TCE

[Lenny Siegel <lsiegel@cpeo.org>]

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reply submitted by Brooks Koenig <BrooksKoenig@comcast.net>:

Larry,

I think it is INappropriate to use OSHA PELs as ARARs.

As you note, the OSHA standards are old; they are often based on acute
exposure; they are typically far less stringent than what should be the
appropriate chronic level ARAR; and, finally, they can be grossly
mis-applied to commercial mixed use developments where more susceptible
populations than adult workers are exposed.

OSHA PELs are not ARARs, but if one exceeds OSHA PELs, you know you need
additonal remediation.

> Submitted by Lawrence Schnapf <LSchnapf@environmental-law.net>:
> 
> I have a question about the relevancy of the OSHA PEL where  VOCs such
> as PCE or TCE are detected in indoor commercial space at levels below
> OSHA PELs. Does anyone know if the OSHA PEL can be used as an ARAR? I am
> concerned that the OSHA PELs are numbers derived from the 1970s so that
> they do not reflect the latest science, and obviously time-weighted over
> an 8 hour period. I have found some consultants using the OSHA PEL as a
> remediation standard and am somewhat dubious that the OSHA PEL can be an
> appropriate standard to use when determining if indoor air
> concentrations are at levels that require remediation or at least
> disclosure to workers.
> 
> Larry
> 
> Lawrence P. Schnapf, Esq.
> 55 E.87th Street #8B
> New York, NY 10128
> 212-996-5395 (phone)
> 212-593-5955 (fax)
> LSchnapf@environmental-law.net

--
Brooks Koenig <BrooksKoenig@comcast.net>
Veritas, Vizslas, & Velos
2833 SE Harrison St.
Portland, OR 97214

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