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Why are you telling me about CALOSHA PEL’s?
Part III ADS (Actually Do Something) – The Best People

Barbara Kanegsberg, SQRC

You have a great opportunity to help California achieve effective, efficient, transparent, well-documented PEL’s. PEL’s that provide great worker protection, and high quality critical cleaning processes do not magically fall from the sky. They are designed by people - people with great technical training, experience, and a degree of common sense. Before the end of April, you can nominate the best possible people (from California and anywhere else) to serve on the Health Expert Advisory Committee (HEAC).
Read on for things you can do and for my own wish list. Contact us; we’d love to discuss this!

What can you do?
Ask questions; speak up; get involved.

The PEL process is an important issue. SQRC has provided input to CAL/OSHA. You should weigh in, too.

Call your professional society, advocacy group and/or union. Find out exactly what their stance is and what they plan to do to support protective, realistic, transparent, PEL’s. “Don’t worry your pretty little head about it; we’ve got it wired” is not an acceptable answer. Get details.

Support the positive aspects of the new PEL policy so you can protect your workers, the environment, and your business.

Make sure the best minds available are involved in the Health Expert Advisory Committee (HEAC).Maybe you want to volunteer for the HEAC. Maybe you know someone who should be on the HEAC. They do NOT have to live in California. CAL/OSHA is accepting nominees to the HEAC this month. Nominations with resume or CV should be sent to Steve Smith or Bob Barish by April 30, 2006.

What would I wish for? (Besides world peace)

Additional resources allocated for the PEL process at CAL/OSHA. A volunteer group is time-consuming for participants. Even with the possibility of remote conferencing, smaller groups might not have the fiscal resources to participate.

PEL’s based on risk factors for worker exposure, not community exposure (1). Risks for workers and communities are very different. Resources, ideas, opinions, research papers should be evaluated - but PEL’s extrapolated directly from risk factors developed for communities may not be optimal for worker protection. Unrealistically low PEL’s that drive companies to uncharacterized processes or to flaunting of the rules could increase danger to workers.

PEL’s set by professionals with expertise in risks to workers.

An effective, efficient, transparent, well-documented PEL process at the Federal level.

An “ISO-type” decision tree standard for PEL’s, with regular updates of process chemicals. We need a level playing field for PEL’s to adequately assess worker safety and to design cleaning, surface preparation, and other processes with the appropriate controls. PEL’s are not updated yearly or even every decade. Consider two chemicals; Chemical A has a PEL of, say, 25 ppm; chemical B has a PEL of 274 ppm. The PEL for chemical A may have been set in 2005. The PEL for chemical B may have been set by Noah’s Pediatrician while on a pre-flood junket sponsored by lobbyists for the manufacturers of Chemical B.

A reasonable approach to managing blends, one that recognizes the potential for synergistic chemical interaction.

(1) For an explanation of why community safety levels are developed in a different manner than are worker safety levels, please see “Cal/OSHA PEL’s: Community Standards for Worker Exposure Limits,” (The Green Files, January, 2007,

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