To better protect people from TCE , we must (amongst other things) eliminate the difference between the standard of protection for our workplaces and the standard of protection for our homes. The standard of protection for TCE in the air is an example where the difference between protection at work and home is intolerable.

For those who don't know, the safety of the air in your workplace is governed by standards set by the Occupational Safety and Health Administration (OSHA). The air in your home is governed by guidelines established by the Environmental Protection Agency (EPA). In too many cases, OSHA's standards for the workplace are drastically less protective than EPA's guidelines for homes.

Just how much more TCE does OSHA allow in workers' air? At least several hundred thousand times more than EPA allows in their homes.

The result? Workers are being poisoned...and OSHA is allowing it.

In a March 2007 paper entitled "Regulating Vapor Intrusion: What Standards Should Apply," the authors highlight this disparity in a handy table:

TCE Standards or Guidance Levels for Indoor Vapor Concentration

Regulatory or Standard Setting Body	Standard or Guidance Level (µg/m3)
Industrial Standards and Guidelines
OSHA PEL (8-hour time-weighted average)	537,000
OSHA Ceiling Exposure	1,075,000
American Conference of Governmental Industrial Hygienists (ACGIH) (8-hour time-weighted average)	269,000
National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) (10-hour time-weighted average)	134,000
Residential Guidelines
EPA 2002 Draft Vapor Intrusion Guidance Target Indoor Air Concentration (Table 2c) (using 10-6 risk level)	0.022
EPA 2002 Draft Vapor Intrusion Guidance Target Indoor Air Concentration (Table 2a) (using 10-4 risk level)	2.2

For those who don't know, the OSHA standard above was set based on 1967 standards and has remained the same to this day. With all we have learned about TCE's dangers since 1967 - including that it causes cancer and other significant diseases/health problems - workers remain as exposed and at as much risk of TCE-induced disease as workers of nearly 40 years ago.

Why is the air at work hundreds of thousands of times less safe than the air at home? How many people are poisoned by TCE at work to this day because of this disparity?

Of course, TCE is just one example of a chemical where workplace protection standards are outdated. Over at The Pump Handle, a blog that bills itself as a water cooler for the public health crowd, we learn that Beryllium is another example.

In a post entitled "Why do OSHA Standards Remain the Same, Even When the Science Changes?" David Michaels describes his look at outdated workplace exposure standards for Beryllium. Any of this sound familiar?

In a 1947 report, entitled Public Relations Problems in Connection with Occupational Diseases in the Beryllium Industry, the Atomic Energy Commission (AEC) asserted that the ability of the US government to produce nuclear weapons was threatened by the high incidence of severe health effects associated with exposure to beryllium, a metal vital to weapons production. In response, the AEC established a workplace exposure limit that dramatically reduced beryllium disease incidence. This limit is known as the “taxicab standard” since it was determined by two AEC scientists working in the back seat of a taxi on their way to a meeting.

Over the next several decades, however, increasingly powerful evidence accumulated that Chronic Beryllium Disease (CBD), a progressive and irreversible inflammatory lung disease, was associated with exposure to levels below the “taxicab standard,” and by the 1990s, scores of workers employed in the production of nuclear weapons had been diagnosed with CBD.

Attempting to prevent strengthened government regulation, and to avoid negative publicity that would discourage use of the metal, the beryllium industry waged a concerted effort over decades to counter the accumulating scientific evidence of beryllium’s toxicity. The industry relied on expert services provided by a major public relations company and a leading ‘product defense’ firm. Eventually, when the scientific evidence became so great that it was no longer credible to deny that workers developed CBD at levels permitted by an out-dated standard, the industry responded with a new rationale for delay: that more research was needed to determine the best standard.

The industry’s efforts have been, for the most part, successful. While each year brings new studies linking CBD with beryllium exposures below the current standard, the “taxicab standard” remains the limit enforced by the Occupational Safety and Health Administration in private sector workplaces. New CBD cases have been reported recently in metal recycling facilities. US civilian nuclear weapons workers have greater protection than private sector workers; in 1999 the Department of Energy issued strengthened beryllium regulations, reducing the workplace exposure level that triggers protective action by a factor of 10.

The lessons from this case study for public health policymakers include:

• The absence of evidence is not the evidence of absence. The lack of CBD cases in the 1950s should not have been seen as proof the standard was adequate.


• The interpretation of scientific data by those with financial incentives must be discounted. Industry scientists defended the “taxicab standard” long after it was correctly recognized as inadequate by independent scientists.


• In particular, work by scientists employed by firms specializing in product defense and litigation support must be seen for what it is: advocacy, rather than science. This study illuminates the practice of “manufacturing uncertainty,” the strategy used by some polluters and manufacturers of hazardous products to prevent or delay regulation or victim compensation.


• To best protect public health, we must consider the hazards associated with a toxic material through the entire life cycle of the product.