DRI DEFENSE PRACTICE SEMINAR

Asbestos TrialTechniques and

Asbestos MedicineVolume II

816C

October 27-29,

Hotel Inter-Continental MiamiMiami, Florida

THE DEFENSE RESEARCH INSTITUTE750 North Lake Shore Drive, Suite 500

Chicago, Illinois 60611

THE EFFORTS AND INFLUENCE OF THE ACGIH

(A Focus on the TLV Committee)

By

JAMES H. CROSBYCrosby, Saad & Beebe, P.C.

2970 Cottage Hill Road, Suite 210Mobile, Alabama 36606

205/476-3000

S-l

"What is it that is not poisoned? Allthings are poison and none withoutpoison. Only the dose determines

that a thing is no poison."Paracelsus, August 24, 1538

THE EFFORTS AND INFLUENCE OF THE ACGIH

(A Focus on the TLV Committee)

Two chickens, twelve rabbits and Max Gruber were exposed to

varying quantities of carbon monoxide by Max Gruber at the

Hygienic Institute in Munich in 1883. This experiment culminated

in the first threshold limit value (TLV) for carbon monoxide

itwhich was published in the first volume of Archive fur Hygiene.

In the U. S. it was not until 1914 that the modern phrase

"industrial hygiene" had application with the establishment of

the United States Public Health Service Office of Industrial

Hygiene and Sanitation. The "modern" profession of industrial

hygienist probably did not begin in the U. S. until the formation

In the year 1473 a German physician may have providedthe earliest "pamphlet" on industrial hygiene when he describedthe injurious effects of vapors and fumes from silver, mercuryand lead, as well as the toxic effects of fumes from burningcharcoal (carbon monoxide). In his treatise on the subject heoffered goldsmiths and other metal workers the advice to work inthe open, or if they must work indoors to open the windows. Hefurther advised them to turn their faces away from the fumes andkeep their mouths closed and to protect themselves as much aspossible. "An Acceptable Level of Exposure". Zapp, John A.,American Industrial Hygiene Association Journal (38), September1977, p. 425.

of the American Conference of Governmental Industrial Hygienists

(ACGIH) in 1938.2

Prior to 1938 there had been some regulation in modern

industry primarily at the state and local levels, although

federal agencies which were in existence included: the

Department of Labor (1913); the Bureau of Mines (1910); the

Children's Bureau (1912); and the forerunner of the Division of

Occupational Health of the United States Public Health Service -

the Office of Industrial Hygiene and Sanitation (1914).3

Additionally, there existed private organizations such as the

American Association of Labor Legislation (1906) ; the National

Council for Industrial Safety — later the National Safety

Council — (1913) ; the Industrial Hygiene Section of the American

Public Health Association (1914); and the American Association

of Industrial Physicians and Surgeons (first annual meeting

1916). In 1913, the International Ladies' Garment Workers Union

began the original union-sponsored type of medical care plan.

This was followed in 1917 with the incorporation of the Union

4

Health Center.4

Kobert, in 1912, published tables on industrial gases.5 In

1912 the Bureau of Mines Technical Paper 248 contained lists for

33 compounds.6 In 1927, R. R. Sayers published information

about the most important poisonous gases and vapors. This was

followed the next year by Zangger in a German publication that

compiled a table quantifying dosages and the effects of irritant

and poisonous gases and vapors.^

With the "New Deal", governmental responsibility for

workers' safety and health remained primarily with local

governments, however, new laws and regulations relating to

workers were passed, including:

1. The Division of Labor Standards established in the u. S.

Department of Labor.

2. The Social Security Act of 1935 which made federal funds

available to the U. S. Public Health Service for research in

areas including industrial hygiene.

3. The Walsh-Healey Act, passed in 1936, which set labor

5

standards on certain government contracts.

4. The establishment in 1937 of the Industrial Hygiene

Division of the National Institute of Health.

5. The adoption of the Fair Labor Standards Act in 1937,

which set forth the maximum hours and minimum wages for all

workers in interstate commerce.

6. The 1941 Federal Mine Inspection Act which authorized

the Bureau of Mines to make inspections and investigations with

respect to health and safety conditions of mines.

7. The 1948 Labor Relations Board ruling that health and

welfare plans were within the scope of collective bargaining.

These and other federal agencies collected and disseminated

information, conducted field studies, laboratory research, and

regulated federal employee health and safety.8

By virtue of the Social Security Act making federal funds

available for industrial hygiene, the United States Public Health

Service was prompted to initiate a program for the development

and extension of all phases of public health work, including

6

industrial hygiene at the local level. These funds were made

available in 1936 and the United States Public Health Service in

cooperation with the Conference of State and Provincial Health

Authorities of North America began a program to conduct active

industrial hygiene work in state and local health departments.8'9

According to Bloomfield (one of the founders of the ACGIH),

one of the most pressing problems in the 1930's was the lack of

trained personnel to evaluate and control the then inevitable

hazards associated with industrial work. The burden fell

primarily upon the Public Health Service which decided to give

short courses of instruction to personnel selected by various

health departments for work in the field. This consisted

primarily of a four week seminar of lectures on industrial

hygiene administration, health hazards, control methods, as well

as laboratory demonstrations of instruments used for

investigative and control work. The first of these seminars was

conducted in the Summer of 1936 and in the Summer of 1937 a

second seminar was held since the number of people engaged in

7

industrial hygiene had increased from approximately forty to more

than one hundred.10

Since the seminars could do nothing more than provide the

public health worker with an introduction to public hygiene,

additional training took the form of cooperative field

investigations in various states. Asbestosis, for example, was

studied in North Carolina and South Carolina. The study used as

the basis for the asbestos TLV was one of the first usages of

iSocial Security Funds. The health of workers in the ceramic

industry were studied in West Virginia while the hazards of

hatters' fur carroting and the felt hat industry were studied in

Connecticutt.11

It was decided during the last week of the second seminar in

1937 that a non-official organization should be established to

continue the annual seminars. The decision to be non-official

was to allow greater independence. The first annual meeting of

*"A Study of Asbestosis In The Asbestos Textile

Industry", Dreessen, et al., Public Health Bulletin No. 241.(August 1938).

8

the Conference was held in Washington, D. C. on June 27-29, 1938.

Chartered in June of 1938 as the National Conference of

Governmental Industrial Hygienists, the well respected American

Conference of Governmental Industrial Hygienists, became "...

from about 1940 to the passage of the Occupational Safety and

Health Act in 1970, . . . the leading force in promoting U. S.

industrial health standards . . . "12

Those individuals, all engaged in industrial hygiene

activities in government service, set forth in their Constitution

the following objectives:

"To promote industrial hygiene in all itsaspects and phases, and to coordinate such activitiesin official federal, state, local, and territorialorganizations."13

The Conference in 1938 was attended by industrial hygienists

from 25 state units and 3 federal agencies, the Public Health

Service, the Bureau of Mines, and the Tennessee Valley Authority.

The first Secretary/Treasurer was John J. (Jack) Bloomfield of

the Unr .d States Public Health Service.14 [See: "A Study of

Dust Control Methods in an Asbestos Fabricating Plant", Page, R.

9

T. and Bloomfield, J. J., Public Health Reports Vol. 52, No. 48,

Nov. 1937 pp. 1713-1727.]

At the 1940 meeting of the ACGIH in Bethesda, William G.

Frederick (Director, Bureau of Industrial Hygiene/ Detroit

Department of Health) asked which standing committee of the

Conference was responsible for establishing "safe limits or

threshold limits and concentrations". Frederick was promptly

placed in charge of a sub-committee of the Technical Standards

Committee. In 1941, the sub-committee on threshold limits

consisted of: Manfred BowditchPhilip DrinkerLawrence FairhallAl DooleyWilliam G. Frederick (Chairman)15

They were to gather information on the subject of threshold

limit values and report their findings at the Fifth Annual

Meeting in 1942. This first report consisted of the results of a

survey of values used by different states and local agencies for

a number of common exposures. (Attachment "A") These results

were compiled into several tables listing "Maximum Permissible

10

Concentrations". It was not represented as complete, nor was the

data presented as "recommended safe levels". It was presented

without comment. Of note is the section entitled "Dust"

contained in Table I which reveals that as of 1942 South Carolina

set the maximum permissible concentration for asbestos at 15

million particles per cubic foot while California, Colorado,

Massachusetts, Michigan, North Carolina, Oklahoma, and

Pennsylvania utilized 5 million particles per cubic foot

(5mppcf) . [As can be seen from Attachment "B", Massachusetts, in

1940, had no maximum concentration for asbestos.]

Frederick, as Chairman of the TLV sub-committee observed the

following:

"I feel that our sub-committee should assume anactive position in the establishment of working limitsand should issue a list annually to be revised each yearto conform with newer information and the value suggestedby such bodies as the U. S. Public Health Service and theAmerican Standards Association. ...

I feel that a committee like ours, representingnearly all the government enforcing agencies could, withjustification, establish arbitrary limits which appearreasonable, for different classes of material which asyet have been inadequately or not at all investigatedfrom the standpoint of the industrial toxicologist. Thefact that some folks will disagree with such values shoulddo much to stimulate the needed research and investigation.

Then as medical or toxological literature appears

11

which clearly indicates the need for revision^ this canbe done with ease in the annual report. ...

World War II created problems that prevented standing

committee reports in 1943 and 1944, however, in 1944 the TLV

Committee became an independent standing committee of the ACGIH.

At that Conference Manfred Bowditch (Director, Division of

Occupational Hygiene, State Department of Labor and Industries,

Boston, Massachusetts) stated:

"We are dealing here with standards whichcannot be arrived at in the same way that we wouldarrive at the number of threads per inch that shouldbe used on the machine screw of a given size in orderto enable everybody to use screws interchangeably.We are dealing with conditions in factories, as towhich of us are entrusted with the preventativefunctions have got to use our very best judgment. Ifa national body like the ASA decides that 100 partsper million is the proper use for safety and ouragency in Massachusetts is convinced that it is toohigh and that safety demands a figure, we will say,of 50, I feel that we would be absolutely false toour trust, false to the citizens of Massachusettswho are employing us, if we did not throw the higherfigure out the window and stick to the one whichwe believe is required for safety."!

By 1940, the ACGIH, still in its infancy, turned its efforts

to the defense effort of World War II. At the height of the war,

according to Bloomfield, the ACGIH had as many as 70 professional

individuals on loan to the various states to help carry on

12

industrial hygiene work during the war efforts.18

Several months prior to Pearl Harbor the Navy had asked

Harvard and Columbia to provide short training courses for health

work to selected groups of doctors, engineers, and chemists.

Both universities agreed and Harvard provided Philip Drinker (a

leading scientist, industrial engineer and member of the TLV

Committee) who taught three month courses on the subject of

industrial hygiene.19

As a result of these efforts and the efforts of members of

the ACGIH several hundred persons'with a limited amount of

training and experience were able to be "thrown into the breech"

and cope with the many problems associated with the war effort.

The war effort also created an opportunity to expand industrial

hygiene limits to many new areas so that by the end of the war

there existed a series of industrial hygiene units established

throughout the nation in virtually every state, and most large

industrial cities and in several countries.20

During the early periods, governmental industrial hygienists

13

also had the challenge of convincing industries to cooperate with

their investigations into health hazards since the United States

Public Health Service, at that time, did not have legal authority

to enter industrial plants. Investigations were also hampered by

the time and efforts wasted in attempting to convince labor to

submit voluntarily to physical examinations which investigators

needed for their studies of the relationship between health and

working conditions.21

As noted earlier, World War II prevented a meeting of the

ACGIH in 1945, however, a draft report and a list of about 150

maximum allowable concentrations of air contaminants for 1946

were circulated among the committee membership. The report

advised that the MAC's would only be valid in 1946 and proposed

that a list be established with two sets of values, one

physiological and the other optimal. The committee members

rejected the two list suggestion and voted for a single set of

val_2s "to be all things to all people".22

During the proceedings of the Eighth Annual Meeting of the

14

American Conference of Industrial Hygienists held in Chicago,

Illinois, April 7-13, 1946, the Sub-Committee on Threshold Limit

Values presented its report setting forth:

"[a]n extensive list of M.A.C. values — for useduring 1946, with the definite understanding thatit be subject to annual revision."

The values were compiled from the list submitted by the Sub-

Committee at the 1942 meeting, the list published by Warren Cooke

in Industrial Medicine and from published values of the Z-37

committee of the American Standards Association. It was also

noted that many of the values have been used generally by members

of the conference for several years.

In 1948, the various states were requested to provide

information relating to regulations for control of dust in

various industries. Forty-three states and territories responded

providing the following information:

No Regulation Arizona, Arkansas, Indiana, Kansas,Maine, Maryland, Mississippi, NewYork, North Dakota, South Dakota,Vermont (11 states)

Asbestos, five mppcf Arkansas, Massachusetts, NewHampshire, New Jersey, Ohio,

15

ACGIH Standard

Oregon, Wisconsin, Hawaii (8states)

The remaining 23 of the 43responding.^3

The Chairman of the TLV Committee, Dr. L. T. Fairhall (U.S.

Public Health Service) presented the 1948 report on threshold

limits observing, among other things, that there had been some

criticism that the values given were not based upon scientific

evidence. He pointed out that the committee noted that there was

no specific "scientific evidence" presented to substantiate this

criticism. It was re-emphasized that the values are fluid and

subject to annual revision and that they should not be adopted as

fixed or legal values but be used as guides in defining "more or

less safe working conditions". The committee apparently felt

that it would eventually be able to establish definite values

which would give full and ample protection to the worker.24

Throughout the 1940's and 1950's and later the ACGIH

continued to promulgate threshold limit values for various

substances. Beginning in 1954, as a result of certain concerns

16

that the threshold limit values may be misused, the following

statement preceded the table setting forth the established

values.

"Values are given in the following tabulationfor the maximum average atmospheric concentrationof contaminants to which workers may be exposed foran 8-hour working day without injury to health.

These values are based on the best availableinformation from industrial experience, fromexperimental studies, and, when possible, from acombination of the two. They are not fixed valuesbut are reviewed annually by the committee onthreshold limits for changes, revisions or additionsas further information becomes available. Thresholdlimits should be used as guides in the control ofhealth hazards and should not be regarded as finelines between safe and dangerous concentrations.They represent conditions only within which it isfelt that workers may be repeatedly exposed, dayafter day, without their health being adverselyaffected. It is felt, at the present time, thatworkers should not be exposed to a working environ-ment containing any of these substances in excessof the value indicated.

These values are not intended for use, orfor modification for use, in evaluation or controlof community air pollution or air pollution nuisances."

The statement relating to air pollution was apparently added

in view of several inquiries made to the committee on that

subject during the year. Obviously, the ACGIH did not wish for

anyone to become confused as to whether or not the workplace

environment would be appropriate for community air.

17

Additionally, the TLV Committee and the ACGIH decided in

1954 that it would be appropriate to not only provide a list of

"established values" but also a second list of "tentative

threshold limit values" for substances about which there was less

certainty associated with the values assigned. The tentative

list was added because the feeling was that the values given,

even if based on limited information, would at least provide

general guidance. This observation coupled with the previous

experience of long intervals between the development of the first

experimental data and its practical industrial experience

persuaded the Committee that the tentative list was needed, plus

it would serve as a clearing house until such time as the values

were more definitely established.

The tentative list as published also advised that reference

material was available on the substances and that the committee

welcomed suggestions of substances to be added and comments,

additional references or reports of experience with these

materials.25 Clearly, the ACGIH was inviting comment from all

18

who reviewed their threshold limit values with respect to the

appropriateness of the value assigned,

Commencing in 1955, the threshold limit values as adopted by

the ACGIH were published in the AMA Archives of Industrial

Health. Following the introductory language of 1954 and the

listing of "established values", the section on "tentative

threshold limit values" was included. Comments following this

title advised that the values were suggested for further

considerations before being presented for adoption as established

values and invited comments thereon. Additionally, at the

conclusion of the entire list is the statement:

"Reference material has been prepared on eachof the above substances and, though in some instancesrather meager, is available for distribution. Thecommittee would welcome suggestions of substancesto be added and also comments, additional references,or reports of experience with these materials.

As of the 1956 Report of the Committee on Threshold Limits,

more than 3,000 reprints of the 1955 TLVs had been distributed to

various organizations and individuals in the U. S. and abroad.

There were now values for about 250 materials (up about 100 from

19

the 1946 list). Prior to the 1956 report, the Committee, in an

effort to determine the manner in which threshold limit values

were being used by governmental industrial hygienists, sent

requests for such information and,any suggestions for changes or

additions by sending the TLV tables to 56 state, county and city

industrial hygiene units. This resulted in 41 replies that

showed 28 entities used the values as guides while 13 units

advised that the values were being used in the formulation of

codes or regulations.

Additionally, note was made of the information from various

sources concerning certain of these threshold limit values. This

prompted the Committee to encourage the entire membership to

supply information relating to their various experiences:

"[b]ecause of the type of information uponwhich such values have been or should be based.The [ACGIH] is in a unique position to bring forththe data accumulated over years of experience togive expression to these human values as differentfrom animal values. Your obligation in this phaseof industrial hygiene work is great. You may restassured that the committee will give fullest con-sideration to all materin, you supply.

Meanwhile your committee plans to continuethe listing of properly substantiated values fornew materials reported in the literature."

20

The preface to the tables listing the "established values"

as published in the AMA Archives of Industrial Health was altered

in 1956 to reflect the opinion that the TLVs refer to "average

concentrations of 8-hour working shifts rather than a maximum

which is not to be exceeded even momentarily". Also, the

invitation for suggestions and for comments, references, or

reports of experience was relocated as the last sentence of the

preface, rather than at the end of all lists of values.

During the year prior to the report of the TLV Committee for

1957, inquiries were sent by the Committee to 53 state and local

industrial hygiene units to obtain human experience data relating

to threshold limit values. It was also reported that documentary

data was compiled in 1953 and supplemented in 1954, 1955 and 1956

concerning certain materials on the threshold limit list.

One of the concerns of the 1958 annual meeting related to

the misinterpretation and misapplication of TLVs. It was also

noted that 14 states had the ACGIH TLV list as part of their

21

code. It was feared that this could potentially lead to

misinterpretation of the TLVs in legal matters and in diagnosis.

Eventually, under the chairmanship of Dr. Thomas Mancuso the

preface to the TLVs was again modified and a resolution was

passed that:

"... the American Conference of GovernmentalIndustrial Hygienists condemn the improper anddangerous misuse of the threshold limit or MAClist or any similar list by incorporation in anycode, law, rule or regulation as a sole criterionin the determination of a health hazard.^(Emphasisoriginal)

As a result of the TLV Committee review of literature

relating to TLVs it was suggested in 1958 that the thresholds for

three chemicals be lowered based on a recent study and a careful

review of some older data. In 1959, as in the past, inquiries

were received regarding several substances not only from the

United States but also from such distant locations as Australia

and New Zealand. Also, by this time, the information developed

by the TLV Committee was published in the AMA Archives and

reprinted in the Industrial Hygiene Dfqest. the Guide of the

American Society of Heating and Air Conditioning Engineers, and

22

the Mine Safety and Appliances Company. Further, the ACGIH

granted permission to publish the list and a table to be in a new

publication of the British Department of Safety, Health and

Welfare.

Although the Committee must have been pleased that the TLVs

were receiving wide distribution and use, there was still concern

about including these lists in codes. Primarily, this concern

revolved around misapplication of the TLVs by those other than

industrial hygienists and the delay in modifications of codes to

comply with more recent TLVs.28

The report of the 1960 TLV Committee noted that the category

for "mineral dust" would no longer be listed alphabetically but,

rather, by three major classifications: (1) Silica, (2)

Silicate, and (3) Miscellaneous. The Committee also noted a

great number of reports from industry and others with respect ta

threshold limit values relating to several substances (none

asbestos). Finally, the Committee advised that documentation of

all of the threshold limit values appearing on the TLV list had

23

been completed and that it should be published after review and

editing by the Committee.

The 1961 TLVs were the first to be published in a booklet

form and available for purchase. This booklet showed that the

threshold limit values of approximately ten substances were

lowered, primarily as a result of the review of documentary

material.

The "Documentation of Threshold Limit Values" was published

by the ACGIH in 1962. The preface to the document explained that

these were the materials upon which the TLVs were primarily

based. The chief source for these were mainly technical papers

and texts of industrial hygiene and toxicology that had appeared

over th years and from experience and knowledge of Committee

members. Additionally, it was pointed out that informational

sources were referenced and that written communications (when

substantiated by valid observation) were also used to supplement

formally published materials. In other words, comments by those

recognized in the field are utilized, if substantiated.

24

The Committee continued to urge the reader to study the

publication and welcomed suggestions or new data that would

maintain the usefulness of the publication. [A copy of the 1962

"Documentation" pertaining to asbestos is available on request.]

It was noted by Chairman Lynn Schall (New Jersey Department

of Health) in 196828a that in 1962, about 36,000 copies of the

TLV booklet had been disseminated worldwide and that six foreign

countries (including Japan) were allowed to re-print the TLVs in

their native languages. The "Documentation of Threshold Limit

Values" was getting a good deal of review and favorable comments

and because of the increased caseload membership of the TLV

Committee was enlarged to fourteen from its previous number of

eight. Also, a non-voting consultant was permitted on the

committee. (Later, in 1970, the committee was expanded to allow

liaison members, including representatives from industry and

labor.) Additionally, beginning in 1962, partially as a result

of observations by Stokinger beginning in 1956, there was an

appendix at the end of the list of TLVs listing carcinogens - the

25

three listed were benzedine, beta-naphthylamine, and

nitrosodimethylamine.^9

In 1963, Dr. Herbert Stokinger (Chairman of the TLV

Committee) attended the "Second International Symposium on

Permissible Limits for Air," in Paris, France. The Symposium was

arranged by the Sub-Committee on Permissible Limits of Toxic

Substances in Industry with co-sponsorship by the International

Labor Organization and the International Union of Pure and

Applied Chemistry. An observer from the World Health

Organization was also reportedly present. Dr. Stokinger attended

in his capacity as Chairman of the Threshold Limits Committee of

the ACGIH and presented a paper on methods being utilized in the

United States. He apparently was not present as a representative

of the Public Health Service or of the U. S. Government. In

fact, the United States Government apparently was not invited to

send a delegate to what was considered to be primarily a

^i.scussion of experts acting as individual scientists. Dr.

Clark Cooper, a member of the ACGIH, regarded the symposium as

26

being "in the nature of a tentative probing in the field of

international cooperation".30

The 1963 TLV list contained several revisions and additions

as well as changes in the preface. Additional appendices were

inserted having to do with calculating threshold limit values of

mixtures. No new substances were to be added to the tentative

TLV list until it was backed by documented justification. Also,

no revisions were to appear in the 1963 or future lists until

appropriate changes had been made in the justifications that

would indicate the reason for the revision. The revised or new

justifications for 1963 and subsequent years were included in the

1966 edition of the "Documentation of Threshold Limit Values".

[A copy of the "Documentation" for 1966 relating to Asbestos is

available on request.]

Beginning in 1963 "C" designations or "ceiling" designations

were assigned to certain substances because it had been

recognized that the threshold limits of certain acutely-* -ting

substances may not provide a safety factor comparable to that of

27

chronically-acting substances for which a time-waited average

applies. The basis for the "C" listing was provided in Appendix

C of the TLVs. This "C" or "ceiling" listing probably resulted

from a conference with the Z-37 Committee of the American

Standards Association which had previously set maximal acceptable

concentrations as a limiting concentration or "ceiling" below

which all concentrations should fluctuate.

The Transactions of the Twenty-Sixth Annual Meeting of the

American Conference of Governmental Industrial Hygienists in

Philadelphia in April, 1964, recorded the fact that the Threshold

Limit Value Committee had three sub-committees chaired by members

with outstanding competence and experience in the three areas:

(1) economic poisons, (2) organic solvent, and (3) mineral dust.

It was also emphasized that the committee had among its members

leading authorities in these fields. As of 1964 there were 341

threshold limit values (up about 200 from 1946) including

recommended values, mineral dust, and tentative values.

Apparently, as a result of the potential application of the

28

TLVs to the Walsh-Healey contracts, there were suggestions by

industrial employees who contacted the ACGIH that the TLV

Committee should publish a "Notice of Intent" to advise industry

and others of intended actions of the committee prior to taking

any final action on threshold limit changes. The Committee felt

that this would also increase the interchange of toxicologic

information developed by industry and following the meeting by

the committee in December of 1963, a "Notice of Intent" was

publicized by the American Industrial Hygiene Association (AIHA)

"Newsletter" and the ACGIH "Bulletin Board" and subsequently by

the Manufacturing Chemists' Association.

Substances placed on the "tentative list" were to remain for

at least two years or until such time as it became evident that

no further immediate change was a likelihood. As usual, the

committee continued to request and welcome suggestions toward

improving its sources of information, however, it was emphasized

that "final decisions must be those of *".he committee as it is now

constituted, unfettered by considerations other than the health

29

and well being of the industrial worker^"31

The Constitution of the ACGIH was amended at the 1964

Conference to allow membership of the conference to be of three

grades: (1) members, (2) associate members and (3) honorary

members. Previously there were only two grades - members and

associate members. Those eligible for membership were limited

to:

. . .[a]11 persons professionally engaged and regularlyemployed by official governmental units responsiblefor full-time programs of industrial hygiene in anyof its aspects and phases shall be eligible for electionas members of the conference. Governmental personnelemployed in activities of units closely allied, butnot responsible for full-time programs of industrialhygiene, and personnel of educational institutionsengaged in the teaching or in the conduct of researchin industrial hygiene shall be eligible for electionas associate members ofi the conference. Persons whohave been members in good standing for at least tenconsecutive years and who retire while members areeligible for election as honorary members of thisconference."31

The 1968 report of the Committee of Threshold Limit Values

published a "Notice of Intended Changes" for asbestos (all forms)

to 12 fibers per milliliter greater than 5 microns in length or 2

million particles per cubic foot. It was noted that the items

placed in the category of "Notice of Intended Changes" were to

30

remain in that category for at least two years before being

placed among the "Recommended Values". Asbestos remained listed

in this fashion in the TLV booklet in 1969. In 1970 the

recommended value for asbestos was listed as five million

particles per cubic foot, however, the "Notice of Intended

Changes" advised that asbestos would be lowered to five fibers

per milliliter greater than five microns in length.

Also, in 1970, at the direction of the ACGIH Board of

Directors, the TLV Committee was expanded to include liaison

representatives from both labor and industry. Both liaison

representatives accepted an invitation to attend the Spring

meeting of the TLV Committee, however, the union representative

was unable to attend.

At the 1970 Annual Meeting of the ACGIH, Robert D. Gidel,

Assistant Director of the Bureau of Labor Standards, U. S.

Department of Labor, made a presentation relating to OSHA and

Walsh-Healey. His observations included the following:

"Until now, the Federal Government has taken an

31

active role in safety and health only in the limitedareas where federal jurisdiction was clearly indicated,or as an advisor and consultant to states, individuals,and organizations. It has relied on the historicalauthority and responsibility of states to regulate intheir areas, and the responsibility of employers toprovide a safe and healthful place of employment. Itseems, however, that many states and many employershave not properly exercised their authorities andresponsibilities so we have come to a point in timewhen the need for a more uniform and coordinatednational safety and health effort is supported bythe facts."

In the final days of 1970 the Occupational Safety and Health

Act was passed and thereby practically reaffirmed at a broader

federal level industrial air limits that had been official for

about a decade under the Walsh-Healey Act. Clearly, the ACGIH,

realized that the passage of OSH Act would require them to become

involved in educating various individuals to enable them to make

proper inspections for the compliance with these regulations.

iThe ACGIH was prepared to assist in meeting this new challenge.

Dr. Stokinger's report on TLVs in 1972 advised that a

revised listing of carcinogens was to be contained in the TLV

[The "Documentation of the Threshold Limit Values" wasagain revised in 1971. The extensive revision relating toasbestos is available on request.]

32

list as "Appendix A". In 1972 (as in 1971), the designated

"adopted value" for asbestos was inadvertently omitted. (In 1969

the ACGIH discontinued listing TLVs as "recommended" and began

using the term "adopted" for non-tentative substances.) However,

under the category of "Notice of intended Changes Mineral Dust"

asbestos is designated as being revised to five fibers per

milliliter greater than five microns in length. This is followed

by the designation of Ala. "Appendix A" states:

"CARCINOGENS

The committee lists below those substances inindustrial use that have proven carcinogenic in manor have induced cancer in animals under experimentalconditions. Present listing of those substancescarcinogenic for man takes two forms, those for whicha TLV has been assigned (la), and those for whichenvironmental conditions have not been sufficientlydefined to assign a TLV (Ib):

la. Human Carcinogens - Substances known tobe occupational carcinogens with an assigned TLV:

Asbestos, 5 fibers per cc greater than 5microns in length; ...

Ib. Human Carcinogens - Substances known tobe occupational carcinogens without an assignedTLV: [6 substances are listed].

For the substances in Ib, no exposure orcontact by any route, respiratory, skin or oral,as detected by the most sensitive methods, shallbe permitted. . ,."32

33

This is the first time that the sub-categories of

carcinogens were utilized by the ACGIH and is also the first time

that asbestos is designated in one of these categories.

The Transactions of the 1972 Conference mentions the fact

that asbestos has been listed as one of the five target health

hazards by OSHA. It was noted that on December 7, 1971, an

emergency standard for asbestos was set at five fibers per

milliliter greater than five microns in length with

concentrations above five fibers per milliliter with certain peak

exposures permitted. Note is also made that NIOSH in its

"Criteria for Recommended Standard ... Occupational Exposure to

Asbestos", recommends a TLV of 2.0 asbestos fibers per cc greater

than five microns in length determined as a time-weighted average

for an 8-hour day with no peak concentrations of asbestos

exceeding ten fibers per cc greater than five microns as

determined by a minimum sampling time of fifteen minutes.

Based on information presented at the conference, results of

environmental surveys of various asbestos plants had revealed

34

that dust concentrations were generally below the existing

emergency standard and that the surveys indicated that there were

available methods by which dust concentrations to asbestos dust

«could be maintained at or below the existing standard.

On April 28, 1971, the Occupational Safety and Health Act of

1970 became law. The act permitted existing federal standards

previously adopted under Walsh-Healey to be automatically adopted

as occupational safety and health standards on that date.

(Except for the ACGIH list of potential occupational carcinogens

contained in the 1968 report which OSHA did not deem adopted by

Walsh-Healey although the Department of Labor had apparently

recognized these TLVs also). Throughout the 50's and into the

60's the ACGIH had discouraged governments from adopting the TLVs

as laws. The primary concern had been the slowness with which

such laws and regulations could be adopted and modified to

Attached as Attachment "C" is an outline of thesequence of the ACGIH TLVs for asbestos which is reprinted herewith permission of the ACGIH.

Also, copies of the excerpts of the 1978, 1980, 1981and 1986 "Documentation of Threshold Limit Values" pertaining toasbesos, are available on request.

35

reflect recent knowledge and technology. This concern was well

founded. Since 1971 there have been probably 200 revisions in

the ACGIH's TLVs. Because of the requirements of the OSH Act

probably less than half of these have been incorporated by OSHA.

Since 1972, in addition to the joint sponsorship with the

AIHA of the American Industrial Hygiene Conference, the ACGIH has

sponsored various technical symposia that have addressed such

issues as quartz, cotton dust, workplace control of carcinogens,

labelling and warning systems, asbestos identification and

measurement, and industrial hygiene for mining and tunnelling.

The ACGIH continues to publish and distribute technical books,

manuals, guidelines and other professional materials which

include:

1. Transactions of the ACGIH.

2. Annals of the ACGIH.

3. Threshold Limit Values.

4. Documentation of TLVs.

5. Industrial Ventilation - a manual of recommended

36

practice, 18th Edition (1984).

6. Air Sampling Instruments for Evaluation of Atmospheric

Contaminants, 6th Edition (1983).

7. Others. For information write:

American Conference of GovernmentalIndustrial Hygienists, Inc.

6500 Glenway Avenue, Building D-7Cincinnati, Ohio 45211Phone: 513/661-7881

There are numerous currently active ACGIH technical

committees including the threshold limit values for airborne

contaminants and threshold limit values for physical agents.33

CONCLUSION

As noted by Warren Cooke:

"The acceptance of the TLVs of the ACGIH inthe USA was well established by the incorporationof its list of TLVs [by] ... the U. S. Departmentof Labor Occupational Safety and Health Administration(OSHA) safety and health standards. Of the states ofthe USA, 34 used the TLVs as listed by OSHA and therest of the 16 states either'refer to the OSHA listor depend mainly on the updated ACGIH TLVs.

Throughout the world, most of the countries thathave occupational exposure limits have found the ACGIHTLVs of value in developing their own occupationalexposure limits and a number of these have adoptedthe ACGIH list ... worldwide." 34

Even if one chooses to occasionally criticize the ACGIH one

37

must still acknowledge the fact that the ACGIH has been relied

upon by health authorities not only in developing countries but

also that the TLVs have been:

"... very influential over the past 40 years inBelgium, West Germany, Austria, Italy, the Netherlands,Portugal, Denmark, Sweden, Finland, Norway, Spain,Switzerland, the United Kingdom, and Japan. ..." 35

Unfortunately, some of those who have been critical of the

ACGIH may not appreciate that:

"[t]he widespread acceptance and use of ACGIHpublications is due primarily to their quality andobjectivity. Some of their credibility for non-member users derives from the restrictive natureof the ACGIH membership. While many of the technicalcommittees have consultants (non-ACGIH) membersrecruited for their special expertise, voting isrestricted to ACGIH members. Thus, all decisionsregarding recommendations for TLVs, ... are madeby members who have no direct economic interestin the consequences of their recommendations. Theymake their recommendations solely on the basis oftechnically defensible judgments about the effectson worker health protection." 36

The ACGIH has clearly fulfilled a need in the area of

industrial hygiene and continues to do so. Obviously, as with

any fifty year old scientific organization, there were erros.

However, the organization has learned from these and improved as

a result of them.

38

When one looks back over the last seventy-five years of

American industry and considers the conditions existing in the

1920's and compares those conditions to those since 1938 it is

obvious that the ACGIH has been unselfishly instrumental in

protecting the worker and modernizing industry.

The author acknowledges with appreciation the cheerfulassistance of the ACGIH in providing information wheneverrequested and for allowing reproduction of its materials forpresentation with this paper.

39

REFERENCES

2.

3.

4.

5.

8.

9.

10.

11,

12.

13,

14,

15.

16.

17.

"History of ACGIH TLVs", Cook, W. A., Ann. Am. Conf.Ind. Hva.. Vol. 12 (1985) p. 3

"Historical Review of Industrial Hygiene", Corn, J. K.,Ann. Am. Conf. Ind. Hvg.. Vol. 5 (1983) p. 13

Id. p. 14

Id. p. 14-15

"Kompendium der praktischen Toxikologie zum Gerbrauchefur Arzte". Robert, Rudolf, Studierende undMedizinalbeamti. p. 45. Stuttgard (1912)

"Gas Masks for Gas Met in Fighting Fires,"Fieldner, A.C., et al. Bureau of Mines Technical Paper 248.(1921)

"Toxic Limits", Teleky, Ludwig, M.D., Ann. Am. Conf.Ind. Hya.. Vol. 9 (1984) p. 37

Corn, p. 15

"What the ACGIH Has Done for Industrial Hygiene",Bloomfield, J. J., Ann. Am. Conf. Ind. Hvg.. Vol. 9(1984) p. 3

Bloomfield, p. 3

Bloomfield, pp. 3-4

"The Origin and Basis of Threshold Limit Values",Paull, J. M., American Journal of Industrial Medicine,5:227-228 (1984).

Corn, p. 16

"ACGIH: Its Background, Membership, and Activities",Lippmann, Morton. Annals of American Conference ofGovernmental Industrial Hyqienists. Vol. 5 (1983), p.5.

"The Birth of the ACGIH Threshold Limit ValuesCommittee and Its Influence on the Development ofIndustrial Hygiene", Frederick, W. G., Transactions ofthe Thirtieth Annual Meeting of th' ACGIH, May 12-14,1968, St. Louis, Missouri, pp. 40-43 (1968)

Frederick, pp. 40-41

Frederick, p. 41

18.

19.

20,

21.

22,

23.

24.

25.

26.

27.

28.

28a.

29.

30.

"What the ACGIH Has Done For Industrial Hygiene",Bloomfield, J.J., Annals of the American Conference ofIndustrial Hygienists, Vol. 9 (1984), p. 5.

"Chronology of Asbestos Regulation in United StatesWorkplaces". Nowinski, P. A. Asbestos-RelatedMalignancy. Anteman and Aisner, ed., p. 101-102

Bloomfield, p. 5

Bloomfield, p. 7

Frederick, p. 42

Nowinski, p. 113

Annals of American Conference of Industrial Hygiene,Vol. 9 (1984), p. 347

Transactions of the Sixteenth Annual Meeting of theAmerican Conference of Governmental IndustrialHygienists, Chicago, Illinois, April 24-27, 1954,pp. 22-26, 34-42

"Threshold Limit Values for 1955", Coleman, Chairman,et al. AMA Archives of Industrial Health, June 1955,Vol. 11, pp. 521-524

Transaction of the Twentieth Annual Meeting of theAmerican Conference of Governmental IndustrialHygienists, Atlantic City, New Jersey, April 21-22,1958, pp. 138, 175

Transactions of the Twenty-First Annual Meeting of theAmerican Conference of Governmental IndustrialHygienists, Chicago, Illinois, April 18-21, 1959, pp.94-95, 105-107

Transactions of the Thirtieth Annual Meeting of theAmerican Conference of Governmental IndustrialHygienists, St. Louis, Missouri, May 12-14, 1968, pp.10-43, 141-146, 188-191

Transactions of the Twenty-Fourth Annual Meeting of theAmerican Conference of Governmental IndustrialHygienists, Washington, D. C., May 12-15, 1962, pp. 91,100-102, 118-131

Transactions of the Twenty-Fifth Annual Meeting of theAmerican Conference of Governmental IndustrialHygienists, Cincinnati, Ohio, May 6-10, 1963, pp. 39-40

31. Transactions of the Twenty-Sixth Annual Meeting of the

American Conference of Governmental IndustrialHygienists, Cincinnati, Ohio, April 25-28, 1964, pp.23-33, 36, 100-101, 109-111

32.

33.

34.

35.

36.

TLVs, Threshold Limit Values for Substance in WorkroomAir adopted by ACGIH for 1972

"ACGIH: Its Background, Membership and Activities",Lippmann, Mortan. Ann. Am. Conf. Gov. Ind. Hyg.. Vol.5 (1983), p. 6

"History of the ACGIH TLVs", Cooke, W. A., Ann. Am.Conf. Ind. Hya.. Vol. 12, (1985), p. 9

"Corporate Influence on Threshold Limit Values",Castleman, B. I. and Ziem, G. E., American Journal_ofIndustrial Medicine. 13:531-559 (1988)

Lippman, p. 6

The third annual meeting of the national Conference of Qovemmental Industrial Mygienist held in Bethesda, Maryland, April30 through May 2,1940 provided the forum or set the stage for the beginning of Threshold Umlt Values Committee as it isnow known. History Informs us that at this meeting a sub-committee was established for this purpose as a part of theCommittee on Technical Standards. Discussions were held as to whether or not these values should be considered as"regulations passed upon by a national organization." Mo decision was reached at that time,

At the next meeting held in Washington D.C In February 1941. the Subcommittee on Threshold Limits had not yet begunto function. The committee was charged with the task of digesting all of the information currently available and reporting tothe conference at the annual meeting In 1942. The report presented follows.

APPENDIX A

Report of the subcommittee on threshold limits*

The Subcommittee on Threshold Limits pre-sents the attached table (Table I) of maximumallowable concentrations of atmospheric contam-inants as Its first report to the Conference. Thetable was prepared from lists furnished by variousState units. It is not necessarily complete becausesome States did not reply. Others indicated thatthey used a list furnished by the U.S. Public HealthService. Inquiry revealed that the U.S. Public HealthService now considers that list not "applicable inthe light of present knowledge."

The table is not to be construed as recom-mended safe concentrations. The material is pre-sented without comment

Supplementary to the table of concentrations isa summary of the activities of the American Stan-dards Association (Table II] and a list of maximumallowable concentrations of various substances asproposed by various authorities (Table III].

' Published in 7>ans. of Fifth Annual Meeting of the nationalConference of Gouemmenta/ Industrial HygienisLs. pp.163-170 (1942). A joint meeting with me Subcommittee onIndustrial Health and Medicine, Health and Medical Com-mittee, Federal Security Agency, April 9-10, 1942. Wash-ington, DC

TABLE IMaximum Permissible Concentrations of Atmospheric Contaminants

as Recommended by Various State Industrial Hygiene Units(Expressed in ppm, except for those with an asterisk, indicating mg/m' i

Substance

Acetone

Aliphatic acetatesAmmonia

Amyl acetate (n)

AnilineArsenic trioxide

Arsme

Benzene

Bromine

Butanol

Butyl acetate

Cadmium

Concentration

ZOO

500

100

500400

5

0.5'

1

10075-100

75

1

100

500400

o.r

States

Calif.,

Mich.

Calif.,Mich.Calif..

Calif..

Okla.

Calif..

Calif..Kans.

Colo.

Colo.,

Colo.,

Colo.,

Colo,

Colo.

. Kans.

. Kans.

, Kant.

Kans.

. Conn

, Mass., Mich., Minn.. Okla Wis

. Ky.. Mass., Minn., Okla , Wis

. Mass., Minn , Wis.

, Mass . Minn , Okla,. Wis.

., Pa., S.C.

Ky.. Md.. Mass., Mich,, Minn.. Ohio, Okla , Wis.

Mich.

Calif.,MichCalif.,

Calif.,

Cole...

Colo.,

Colo.,

Kans

Kans.

Kans

.Okla

, Ky., Mass.. Minn-, Okla . Pi . Wis.

, Ky., Mass.. Minn., Okl*., Pi . Wis

Ann. Am, Cnnf. InO. WJJJ.. VoL 9(1994!ATTACHMENT "A"

Thirty-five Years of TLVs

Substance

Carbon dioxide

Carbon disulfide

Carbon monoxide

Carbon tetrachloride

Chlorine

Chlorodiphenl

Chloroform

ChloronaphthalenesChloronaphthalenes

(above "tn")Chloronaphthalenes "tri"Chloronaphthalenes

"penta"Chromium — hexavalent

(chromic acid)

Dichlorbenzene

Dichlorethylene (trans)

Dichlorethyl ether

Ethanol

Ethyl chloride

Ethyl bromide

Ethyl ether

Ethylene dichlonde

Formaldehyde

Gasoline

Hydrogen chloride

Hydrogen cyanide

Hydrogen fluoride

Hydrogen sulfide

Iron oxide fume (FejOa)Lead

Magnesium oxide fume

Manganese

Mercury

Methano!

Methyl bromide

Methyl chloride

Monochlorbenzene

Naphtha

Concentration

5500

2015

100

100

75

1

1*

100

1-5*

1*

y

o.y

0.1*

o.i*75

100

15

2SO

2000

1700

400

100

20

1000

10

20

3

SO20

15*

0.15*

IS*

SO'6*5*

0.1-0.2*0.1S*0.1*

200100

50

500

75

SOOO

States

Calif.. Colo.

Conn., Ky., Mich., Pa.Calif., Colo., Kans., Matt., Minn., Okla., Wii.

Calif., Colo., Conn., Kans., Ky.. Md., Mat*-, Mich.. Minn.. Ohio,S.C. , Wis.

Calif., Colo.. Conn . Kans , Ky., M.D.. Mai*.. Mi**., Ohio, Okla..S.C.. W,s,Mich.Calif , Colo , Conn., Kim., Ky., Md . Mat*., Mich.. Minn.. OkU .

Calif . Colo.. Kans . Ma**., Minn.. Okla., Pa., Wi*

Calif , Colo.

Kans., Mass., Minn., Pa., Wi*

OklaCalif., Colo., Okl*.

Calif.. Colo.

Calif., Colo . Conn.. Kans., Ky., Ma**., Mich., Minn., Ohio, OklaMd (for electroplating only)

Calif , Colo., Kans., Mass., Minn.. OkU. Wi*.

Ky

Calif., Colo., Kans., Ky , Mass.. Minn.. OkU , Wis

Calif , Colo

Calif., Colo.

Calif.. ColoCalif., Colo , Kans., Mass., Minn.. Okla., Wis,

Calif., Colo . Kans., Mass., Mich., Minn., Okla , WisCalif., Colo.. Conn.. Kans., Ky., Md.. Mass.. Mich , Minn., Okla..Wis

Calif , Colo . Conn.. Kans., Ky., Md., Mass.. Minn.. Okla., S.C. \

Calif., Colo., Conn , Kans., Ky., Md.. Mass., Mich., Minn.. OkU..

Calif., Colo.. Conn., Kans., Ky., Md.. Mass., Mich., Minn., Okla.,

Calif., Colo.. Conn . Kans , Ky.. Md., Mass , Mich.. Minn . OkUWis.

S.C.Calif., Colo., Conn., Kans , Ky.. Md.. Mass , Mich.. Minn . Okla.,

Mich.Calif.. Colo., Conn.. Kans., Ky , Md., Mass , Mich . Minn., Ohio.S.C., Wis.

Mich.Calif., ColoKan*., Okla.Ky

Calif.. Colo.Okla.Conn., Kans., Ky., Mass.. Mich.. Minn., Ohio. Wis.

Kant.. Mass., Mich., Minn.. Okla., Wi*.Calif.. <~-.lo , Conn., Ky . Md., S.C.

Calif., Colo.

Calif.. Colo.Calif.. Colo., Kanv, Mass., Minn.. Okla.. Wi*.

Calif , Colo.

OkU.. P»..

Pa..

S.C., Wi*.

, Pa.. W,*

P a . S C

ftis

S.C. W*

S.C., Wi*.

. S.C..

Pa.. Wit

Okla. Pa .

Ann. Am ,snt. lint 5 19M

Appendix A

Substance

Nitrobenzene

Nitrogen oxides

Ozone

Petroleum vapors

Phosgene

Phosphme

Phosphorus trichloride

Sulfur dioxide

Tetrachloroe thane

TetrachloroethyleneTetrachloroethylene

(perchloroethylene)Toluene

Tnchloroethylene

Turpentine

Xylene

Zinc oxide fume

Concentration

51

29-704010

10.1

1000

12

0 7

10

10

200

100

200

100

200

100

700

200

200

100

15-

States

Kans , Mass., Minn,, Okla , WisCalif,, Colo.

KansConn, Ky , Okla., S.CCalif., Colo , Md., Mass,, Mich., Minn., Minn., Wi*.

Calif., Colo,, Kans., Mas*., Minn., Okla., Wis,Mich.

Mich.Calif , Colo., Conn., Kans., Ky., Md . Mass., Mich., Minn., Okla., S.C., Wis.

Calif., Colo., Kans., Maw., Minn., Okla , Wis

Calif., Colo.Calif.. Colo., Conn., Kans., Ky.. Md., Mass., Mich., Minn , Okla., Pa., S.C..Wis.Calif., Colo., Kans., Ky., Mass., Minn . Okla., Wis.

Calif.. Colo , Kans., Ky., Mass . Minn., Okla., Wis,

Mich.

Kans , Ky.. Mass.. Mich., Minn . Okla., WisCalif.. ColoCalif.. Colo., Kans., Mass , Minn,. Okla.. WisMich

Calif.. Colo., Conn., Ky., S.C.,Kans., Mass , Mich., Minn,, Okla., W'is.

Kans.. Ky,, Mass., Mich., Minn , Okla , WisCalif., Colo.

Calif , Colo., Kans.. Ky., Mass, Mich., Minn, Okla., Pa , Wis

Dust*(Millions of Mrticles oer cubic foot of air - liftht field count)

Substance

Alundum

A»be»tos

Carborundum

Cement

FeldsparFoundry

Granite

Mica

Nuisance

Pottery

Organic

Pyrophyllite talc

Silica (based on percentageof free silica in the dust)

Count x%10%

Concentration

15

IS

5

15

50

10

25

20

IS

12

25

10

SO

10

so4

SO

2510

550

States

Okla.

scCalif., Colo., Ma« ., Mich , N.C, Oklj., PJ.

Okla.

Calif.

N.C

MassN.C. (cleaning castings)

MinnN.C. (molding)N.C.Mass., Vt.

Mich,N.C.Mass . Mich

Calif., Colo

Calif.. Colo., Mass.N.C. (milling)N.C. (mining)

Kans., Minn., Okla . WisIdaho

Ann MI. Conf. Im). Hyg., MM. 9119641 rage 499

Thirty-five Years of TLVs

Substance

("low")10cr23-35',-"medium""high-over 7J:,over 90°p

SilicatesSlate

Soapstone

Talc

Total dust

Concentration

SO101020555

IS

SOIS

50

50IS

50

States

Mass , Mich.IdahoCalif., Colo.Mass., Mich.Mass., Mich., OhioCalif . . Colo.Conn.Okla.

Mich.Calif.. Colo

Mich.Mich.Calif., Colo.

Mass., OkU

TABLE IIActivities of American Standards Association

American Standards completed:

Carbon monomde 100 ppmHydrogen sulfide 20 ppmCarbon disulfide 20 ppmBenzene 100 ppm

American Standards in development:Nitrous gasesCarbon tetrachlondeMercuryChromic acid and chromatesLeadFormaldehydeToluol

Z.37-1,1941

Z.37-2. 1941

Z.37-3. 1941

Z.37-4. 1941

Emergency Standards completed:

Cadmium 0.1 mg m

Emergency Standards proposed:

ManganeseEther (diethyl ether)ArsenicAntimonyZincXylol

2.35-5,

Vin Ant- Caul Ina. Hyg- W. 9 (19841

Appendix A

TABLE IIIAdditional Maximum Permissible Concentrations as Proposed by Various Authorities

Substance

Acrolem

Iodine

Sulfur tnoxide (as SCh)

Nicotine(tobacco dust)

Toluidme (o-m-p)

X-ray radiation

Concentration

3,3 ppm1 ppm

0.5-1.0 ppm01 ppm

2 ppm

5 mg/m3

30 mgim3

1.0-2.5 ppm6-2J ppm

1 xlO"5

Source

Int. Cnt. Tables 2:318, 1927Los Angeles Department of Health (suggested)

Int. Cnt. Tables 2:320, 1927Matt in Flury & Zernik, Berlin, 1931

Int Cnt. Tables 2:320, 1927

Soviet Industrial Stnd. (L'.S.S.R.)States Sci. Inst. (U.S.S.R.)

Int. Cnt. Table* 2:320, 1927Henderson & Haggard. Noxious Gases, New York. 1927

Mutscheller, Am. J. Roentgen. 13:65 1925

Radium

Radon

Gamma radiation

roentgen unitsper sec (200work hrs permonth I

01 micrograms(by expired air test)

10 '' cunesper liter

01 roentgenunits per workday When incombination, lowervalues for each

Handbook H-27, U.S. Bur. Stands , May 2, 1941

Handbook H-27, L'.S Bur. Stands . May 2, 1941

Handbook H-27. L'.S. Bur Stands., May 2, 1"41

Ann, Am. Conf Ina.

Code for safe concentrations of certain commontoxic substances used in industry*

MAMrRED BOWDITCH.A CK. DrUPIKER." PHILIP DRiriK£R.c H.H. HAGGARD0 and ALICE HAMILTON*ADtrector, Division of Occupational Hygiene. State Department of Labor and Industries, Boston, MA; *Dean and Professorof Pliyr-lology, Harvard School of Publk Health, Boston; cProfes*or of Industrial Hygiene, Harvard School of Public Health.Boston; °Dlrector Laboratory of Applied Physiolofly, Yale University, Me* Haven. CT; EAsst Prof, rmeritus. Harvard Sclioolof Publk Health. Boston, and Consultant Division of Labor Standards, Washington. DC

For some time. Massachusetts has made use ofthe following figures as a guide to manufacturersand others interested in maintaining satisfactoryworking conditions. Many of us feel that the codeson toxic limits now being prepared for the AmericanStandards Association will be some time in ap-pearing and we believe that it would help industryif this list were used in the interim.

It is not implied that observance of these figures

is a guarantee against possible III health of workersexposed, or that medical control can be neglected.Revision of any such table from time to time willalways be necessary.

• Published in J. Ind. Hyg. A Tax. 22:251 (June 194O).Reprinted by permission of the American IndustrialHygiene Association.

TABLE IMaximum Concentration Suggested by Massachusetts

Gas or Vapor

Ammonia

Amyl acetate

Aniline

Arsine

Butyl acetate

Carbon bisulfide

Carbon monoxide

Carbon tetrachloride

Chlorine

Chlorodiphenyi*

Chloronaphthalene

Chromic acid

Dichlorbenzene

Dichlorethyl ether

Ether

Ethylene dichlonde

Formaldehyde

Gasoline

Hydrochloric acid

Hydrogen cyanide

ppm

100

400

5

1

400

IS

100

100

11'

1 to 5'

o.r75

15

400

100

20

1000

10

20

Gas or Vapor

Hydrogen fluoride

Hydrogen sulfide

Lead

Mercury

Methanol

Monochlorbeniene

Nitrobenzene

Nitrogen oxides

Ozone

Phosgene

Phosphme

Sulfur dioxide

Tetrachlorethane

Tetrachlorethylene

Toluene

Tnchlorethylene

Turpentine

Xylene, coal tar naphtha

Zinc oxide fume

ppm3

20

o.is-0.1*

200

75

5

10

1

I

2

10

10

200

200

200

200

200

15'

Mtl l tg r jmvcu meter

Ann.Am.Conf. InO. M«., f<*. 9I19M)

ATTACHMENT "B'

fear

SEQUENCE OF THE ACGIH TLV FOR ASBESTOS

1946 - 1961

1962 - 1967

1 968 - 1969

1970

1971

MINERAL DUSTS

Asbestos - 5 mppcf

MINERAL DUSTSSilicate* (less than 1% crystalline silica)

Asbestos - 5 mppcf

MINERAL DUSTSSilicates (less than 1% crystalline silica)

**A*be«tos - 5 mppcf

••NOTICE OF INTENDED CHANCZS

Asbestos - 12 fibers/ml > 5 u in length,J> or 2mppcfK)

J) AJ determined by the membrane filter method at.4 BOX phasecontrast magnification*

K ) A* counted by the standard impinger, light-field counttechnique.

MINERAL DUSTSSilicates (leas than 1% crystalline silica)

**A«be5tos, all types - 5 mppcf

••NOTICE OF INTENDED CHAN<ZSAsbestos (all types) - 5 fibers/ml > 5 u in length*'

K } As determined by the membrane filter method at 430X magni-fication phase contrast illumination. Concentrations > 5fibert/ml, but not to exceed 10, may be permitted for 15-minute period* each hour up to five tunes daily.

MINERAL POSTSSilicates (less than 1% crystalline silica)

••Asbestos, all typesHotei A value MS not listed, however, it should have been

listed as 5 mppcf.

•*NOTIC1 Of INTENDED CHAN<ZSMIHMAL POSTS

Asbestos (all types) - 5 fibers/ml > 5 u in lengthJ)

J) As determined by the membrane filter method at 400-4SOXmagnification (4 •» objective) phase contrast illumination.Concentrations > 5 fibers/ml, but not to exceed 10, may bepermitted for 15-minute periods each hour up to five timesdaily.

ATTACHMENT "C*

1972

1973

1974

MINERAL DUSTSSilicates « 1% quartz)

••Asbestos, all typo

Norg; A values was not listed, however, it should have beenlisted as 5 mppcf.

**NOTICE OF INTENDED CHANCZSMINERAL DUSTS

Asbestos (*ll type») - 5 fibers/ml > 5 u in length;Ala

n)

A1a: Appendix A. Carcinogens1a. Human Carcinogens - Substance* teiown to be occupational

carcinogens with an assigned TLV,Asbestos, 5 fibers/cc > 5 «* in length.

Note; Appendix A on Hot ice of Intended Changes

n) Same as J) for 1971.

MINERAL DUSTSSilicates « 1% quartt)

•• Asbestos, all forms

Note: A value was not listed, however, it should have beenlisted as S mppcf.

••NOTICE OP INTENDED CHANGESMINERAL DUSTS

Asbestos, all forms* - 5 f iberm/cc > S u in length;")Ala

Ala: Appendix A - Carcinogensla. Hunan Carcinogens - Substances recognized as occupational

carcinogens with an assigned TLV:Asbestos, all forms, S fibers/cc > 5 um in length.

n) As determined by the membrane filter method at 400-4SOXmagnificaiton (4 mm objective) phase contrast illumination.

fA more stringent TLV for crocidolite may be required.

MINERAL OUSTSSilicates « 1% quartz)

•Asbestos, all forms* - 5 f iberm/cc > 5 \m inlength;") Ala

•1974 AdditionfA more stringent TLV for crocidolite may be required.n) As listed for 1973.Ala: As listed for 1973.

Year

1975 - 1976

1977

1978 - 1979

1980

Lasting | [ _ ___ _ ^

As 1974 except for Appendix A now defined as: OccupationalCarcinogens, la. Human Carcinogens. Substances, or substancesassociated with occupational processes, recognized to havecarcinogenic or cocarcinogenic potential, with an assignedTLV.

Asbestos, all forms* - 5 f iberm/cc, > 5 u in length.

•Cigarette smoking may substanially enhance the incidence ofbronchogenic carcinoma from this and others of these listedsubstance* or processes.

A* 1975-1976 except Appendix A adopted.

MINERAL DUSTSSilicate* « 1% quartz)

••Asbestos, all forms (5 fib«r«/cc > 5 u» in lengths)Ala)

m) Sane as n) for 1973.

*"Notice of Intended ChangesAsbestos

Amosite 0. 5fiber/cc, A1aChrysotile 2 fibers/cc, AlaCrocidolite 0.2fiber/cc, AlaTremolite 0.5 fiber/cc, A1aOther forms 2 fibers/cc, Ala

Ala. Human Carcinogens.••Asbestos, all foms* (5 fibers/cc, > 5 urn in length)

••See Notice of Intended Changes•Cigarette smoking can enhance the incidence of respiratorycancers form this and other of these substances or processes.

MINERAL POSTSSilicates (< 1% quart!)

•AsbestosAmosite 0.5 fiber > 5 um/cc, A1aChrysotile 2 fibers > 5 um/cc, AlaCrocidolite 0.2 fiber > 5 um/cc, AlaTremolite 0.5 fiber > 5 um/cc, A1aOther forms 2 fibers > 5 um/cc, Ala

Note; Ibotnote 1) should have been carried for asbestosvalues*

1) Same as n) for 1973.•1980 Addition.

1980 (con ' t )

1981

1982-1983

Ala . Human Carcinogens,ttAsbestos

Amosite 0.5 fiber > 5 ura/ccChrysotile 2 fibers > 5 un/ccCrocidolite 0.2 fiber > 5 um/ccTremolite 0.5 fiber > 5 un/ccOther forms 2 fibers > 5 um/cc

t t l980 Adoption

MINERAL DUSTSSilicates ( < l%_gu«rtx)

AftbestosAnosite 0.5 fiber > 5 un/cc, A laChrysotile 2 fibers > 5 un/cc, AlaCrocidolite 0.2 fiber > 5 un/cc, A1aOther forms 2 fibers > 5 un/cc, Ala

Note: Footnote 1) should have been carried for asbestosvalues.

1) Same as n) for 1973.

Ala . timan Carcinogens.Asbestos

Amosite 0 . 5 f i b e r > 5 un/ccChrysotile 2 fibers > 5 UM/CCCrocidolite 0.2 fiber > 5 un/ccOther forms 2 fibers > 5 um/cc

MINERAL DUSTSSilicates « 1% quartz)

AsbestosAmosite [12172-73-5] 0.5 fiber > 5 um/cc, A1aChrysotile

[12001-29-5] 2 fibers > 5 un/cc, AlaCrocidolite

[12001-28-4] 0.2 fiber > 5 un/cc, A1aOther forms 2 fibers > 5 un/cc, Ala

Mote; Footnote 1) should have been carried for asbestosTalues.

1) SASM as n) for 1973.

Ala. Hu*e.n Carcinogens<Same as 1981

Listinq

1984 DUSTSSilicates and Other Dusts « 1% quartz)

1 98 5-1986

Aoosite[12172-73-5] ...... 0.5 fiber/cc > 5 urn in length, A1a

Qjryiotile[12001-29-5] ...... 2 fibers/cc > - urn in length, Ala

Croeidolite[12001-28-4] ...... 0.2 fiber/cc > 5 un in length, Ala

Other form ......... 2 fiber »/ce > 5 on in length, Ala

A1a. Human Carcinogens.A*be«to*l)

Amosite[12172-73-5] ...... 0.5 fiber/cc > 5 UB in length

Qiryaotil*[12001-29-5] ...... 2 fib«r»/ce > 5 urn in length

Crocidolite[12001-28-4] ...... 0.2 fiber/cc > 5 uffl in length

Other form* ......... 2 fitxrs/cc > 5 x» in length

1) Sam* as n) ' - 1973.

DUSTSSilicatet and Other Du«ti « 1% quartx)

AJbeitoi(X) ' "AAoeite

[12172-73-5] ...... 0.5 fiber/ cc. < D AUChry«otil«

[ 1200 1-29- S] ...... 2 fibera/cc,d) AlaCrocidolite

[12001-28-4] ...... 0.2 fiber/cc,(D AlaOther foro» ......... 2 f ib«r«/cc,< A1a

A1a. Hvnan Otrcinogeni.A«beato«()c)

Aaocite[12172-73-5] ...... 0.5 fib«r/cc,(l)

Oiryeotile112001-29-5] ...... 2 fib«r^cc,<D

Crocidolite(12001-28-4] ...... 0.2 fiher/cc,(D

Other for«« ......... 2 fib*r«/cc,( l)

(k) Aa determined by the membrane filter net hod at 400-450 Xmagnification (4 am objective) phase contract illunina-tion.

(1) Fibers longer than 5 UB and tdth an aspect ratio equal toor greater than 3t 1*

Year Listing

1987 to present DUSTSSilicate^

Asbestos* <3)Amosite

[12172-73-5] 0.5 fiber/cc, A1Qirysotile

[12001-29-5] 2 fibers/cc, AICrocidolite

[12001-28-4] 0.2 fiber/cc, A1Other forms 2 fibers/cc, A1

(d) Fibers longer than 5 w and with an aspect ratio equal toor greater than 3:1 as determined by the membrane filtermethod at 400-450X magnification (4 mm objective) phasecontrast illumination.

; Redefinition of the carcinogen designation* adopted in 1987; full text isreproduced below.

APPENDIX ACarcinogens

The Chemical Substances Threshold Limit Values Committee classifies certainsinstances found in the occupational environment as either confirmed or sus-pected human carcinogens. The present listing of substances which have beenidentified as carcinogens takes two forms: those for which a TLV has been as-signed and those for which environmental and exposure conditions have not beensufficiently defined to assign a TLV. there a TLV has been assigned, it does notnecessarily imply the existence of a biological threshold; however, if exposuresare controlled to this level, we would not expect to see a measurable increasein cancer incidence or mortality.

The TLV Committee considers information from the following kinds of studies tobe indicators of * substance's potential to be a carcinogen in hvnans: epidemi-ology studies, toxicology studies, and, to a lesser extent/ case histories. Sci-entific debate over the existence of biological threshold* for carcinogens isunlikely to be resolved in the near future. Because of the long latent periodfor many carcinogens, and for ethical reasons, it is often in possible to basetimely risk- management decisions on result* fro* hunan studies.

In order to recognise the qualitative differences in research results, twocategories of carcinogens are designated!

andXI -- Confirmed Human Carcinogen*

A3 -- Suspected Human carcinogens

Exposures to carcinogens must be kept to a minjnum. Workers exposed to Ai car-cinogens without a TLV should be properly equipped to virtually eliminate allexposure to the carcinogen. Tor AI carcinogens with a TLV and for A2 carcino-gens, worker exposure by all routes should be carefully controlled to levelsconsistent with the experimental and huvan experience data. Please see the Doc-umentation of the Threshold Limit Values for more complete description and deri-vation of these designations.