of the Act (29 U.S.C.

employees on all shifts. Employees cluding trained personnel. Monitoring 657) requires employers to promptly working in the same area doing differcould not be generally concluded notify an employee who is exposed in ent jobs may have different exposures. during a few days, but would necessarexcess of the permissible exposure Therefore the standard requires samily be carried out over a longer period limit. The proposal required that the pling for each job classification as of time. employee be notified in writing within well. The samples are to be full-shift Therefore OSHA has lowered the 10 days of the sampling. OSHA agrees samples to give a more accurate indicamonitoring frequency. with the statements by some industry tion of an employee's average expo- Any choice of a lower measurement participants that 10 days would not sure during a work shift than would frequency is judgmental. OSHA now allow sufficient time for sample analysampling for less than a full shift. believes that requiring measurements sis (Ex. 3D). This would be particular- Short-term samples would tend to be at 3 and 6 month intervals in the cirly true in such cases where many samaffected by the variability or inorganic cumstances of the particular indusples need be analyzed or where samarsenic emissions associated with opertries affected by this standard will reples would be sent to other locations ations such as copper smelting. Fullflect employee exposure with suffifor analysis. Accordingly, the standard shift samples tend to average out cient accuracy to assure that suitable requires an employer to notify each these variations. As time is needed to precautions will be taken as needed. employee in writing of that employee's issue and retrieve samplers, full shift The standard requires that in those measurement within five working days sampling is defined as sampling for at instances in which measured exposure after the receipt of the results of any least seven working hours. The proranges between 5 and 10 µg/m³, these required measurements. posed standard did not expressly set measurements shall be repeated at ASARCO (Ex. 111, Attach. 10; Ex. forth these requirements for accurate least every 6 months. OSHA recog- 1608) twice sent inorganic arsenic sammonitoring. The standard has been nizes that the accuracy of monitoring ples for analysis by outside laboratoclarified by requiring these procedures and measurement will decrease as exries. In contrast to the second trial, for the reasons stated above. All of posure decreases below 10 µg/m³. samples were not replicated and were those requirements are intended to Therefore, the standard requires an not distributed on a double blind basis ensure that the monitoring is truly accuracy of plus or minus 35 percent in the first trial. Therefore, the results representative of an employee's exporather than 25 percent for exposures of the first trial are not as significant sures. between 5 and 10 µg/m³. However, peas those of the second trial. Paragraphs (d)(1) and (d)(2) of the riodic measurement is appropriate In the second trial, five laboratories proposed standard allowed the emwhen exposures are in the 5-10 µg/m³ randomly chosen from the 7 laboratoployer to visually inspect each work range because of the possibility that ries used in the study, were sent one place and work operation to accurately minor changes in process, materials, or blank, filter three filters containing FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 19616 RULES AND REGULATIONS 2.5 µg arsenic and three filters con- ASARCO noted that possible conwork practices to maximize their effectaining 6.0 µg of arsenic. The two retamination might significantly elevate tiveness. Consequently, the final maining laboratories were sent one results at the small sample size range standard allows joint use of engineerblank filter as well as one filter each of the proposed action level of 2 µg/ ing and work practice controls. Respicontaining the other two concentra- m³. The potential effects of contamiratory protection may be used only tions. The results of the second trial nation have been reduced in the final during the time period necessary to inare found in Table III of "Results of standard due to the increased TWA stall engineering controls, where engi- Trace Arsenic Analyses Performed by limit and action level. The sample size neering controls may be inappropriate Various Laboratories" (Attached to collected at the 10 µg/m³ TWA limit such as during some maintenance op- Ex. 160B). will be 5 times greater than at the proerations or in those cases when both The results indicated that 5 of the posed 2 µg/m³ action level. Thus a simengineering controls and work praclaboratories did not achieve an accurailar level of contamination will only tices do not succeed in reducing expocy of plus or minus 25 percent for the have one-fifth the effect. Similarly, an sures below the permissible exposure arsenic samples analyzed. However, 2 equivalent level of contamination at limit. of the laboratories (including the the 5 µg/m³ action level will have only This compliance strategy has been ASARCO laboratory, Laboratory B in 40 percent of the effect which would consistently OSHA's policy and has the table) did achieve accuracies of occur at a 2 µg/m³ level. Therefore a been followed in prior standards and plus or minus 10 percent. level of contamination of 0.5 µg sugproposed standards. This policy is The final standard requires that the gested by ASARCO as a possibility will based upon the view that the most efmethod and measurement have an acnot be a major factor relative to the fective means of controlling employee curacy of plus or minus 25 percent sample sizes resulting from monitoring exposure is to contain emissions of (with a confidence level of 95 percent) at the permissible exposure limit and toxic substances at their source for concentrations of inorganic arsenic action levels in the final standard. through the use of mechanical means greater than or equal to 10 µg/m³. It One question raised was whether combined with work practices. This is requires a method of sampling with an particulate sampling methods could far more effective than reliance on the accuracy of plus or minus 35 percent efficently collect arsenic released in highly variable human behavior so for concentrations of inorganic arsenic the smelting environment. It has been critical to the successful use of respirabetween 5 and 10 µg/m³. suggested that arsenic trioxide has a tors. As discussed below, respirators As noted previously, the standard resignificant vapor pressure and that it have many disadvantages which prequires full shift personal monitoring would not be efficiently collected at clude primary reliance or co-reliance (minimum 7 hours) for the determinathe elevated temperatures of copper of respiratory protection on an equal tion of employee exposure. Using persmelting. An ASARCO study (Ex. basis with engineering and work pracsonal monitoring pumps at a flow rate 160B) indicates the efficient collection tice controls. Furthermore, the burden of 2 liters per minute, with a 7 hour is possible at the temperatures of of reducing employee exposure should sampling time, 8.4 µg of inorganic arcopper smelting. Using millipore permore properly rest on the employer in senic will be collected if the airborne sonal monitor cassettes (0.8 micron whose establishment toxic substances concentration is 10 µg/m³. The equivapore size), backed up by midget imare released rather than placing/the lent sample at airborne concentrations pinger containing potassium permanburden of respirator use on the exof 5 µg/m³ will be 4.2 µg of inorganic ganate or sodium hydroxide, ASARCO posed employee. arsenic. observed that the millipore filter had ASARCO appeared to propose an al- The ASARCO tests indicate that acbetter than 95 percent collection effiternative compliance strategy (Ex. 29 curacies of plus or minus 10 percent ciency of arsenic in the smelter (Ex. p. -; Ex. 111-7, p. 19; Ex. 118). Biologican be achieved by experienced labora- 160 B, Refs. 8, 9). As can be calculated cal monitoring would be used, using an tories with samples of between 2.5 and from Table 1, Ex. 160B; capture effiassumed safe urinary arsenic level of 6 µg of inorganic arsenic. Therefore ciencies ranged from 98.5 percent to 250 µg/liter as a trigger. In those inthe minimum amounts of arsenic 99.6 percent for total arsenic particustances in which the urinary arsenic which would be collected under the late ranging from 45.6 to 224.8 µg/m³. levels were above 250 µg/liter, workers final standards requirement fall The vapor and/or submicron particuwould be removed, and/or engineering within the range which can be acculate evading capture ranged from 0.26 controls or respiratory protection rately analyzed by experienced and to 0.62 µg/m³. Thus, assuming that the would be instituted. ADL (Ex. 111-7) qualified personnel such as those at highest value (0.62 µg/m³) was eluding suggested this would be a much less ASARCO's own laboratories. It is also collection with an airborne concentracostly approach. However, ADL did sufficiently large so that sample comtion of 10 µg/m³, 93.8 percent collecnot include the costs of engineering tamination will not excessively affect tion efficiency would result. controls to reduce exposures in areas the results. It should be noted that the labora- F. METHODS OF COMPLIANCE: PARAGRAPH in which the urinary levels were contory methods used by the two labora- (g) sistently above, the specified limit. Therefore the ADL cost estimate is tories with best results were atomic The final standard requires that enonly a fraction of the actual costs absorption and colorimetric methods. gineering controls and work practices unless it was proposed that employees These methods are relatively simple be used to control employee exposure be constantly rotated from areas of methods commonly in use by industrito inorganic arsenic, except to the lower exposure to those of higher exal hygiene laboratories. More sensitive extent that the employer can show posure and conversely, to reduce high methods are available, such as X-ray they are not feasible. If all feasible enexposures. fluorescence and d.c. discharge emisgineering and work practice controls OSHA does not believe this is an apsion methods (Ex. 145). These more do not succeed in reducing exposure propriate compliance strategy. As dissensitive methods can be used to anabelow the permissible exposure limit, cussed in the monitoring section, there lyze with improved accuracy much they must be supplemented by respirais a weak correlation between urinary lower arsenic concentrations. However, tory protection. This is changed from arsenic levels and environmental arthese methods are somewhat more difthe proposal which required that all senic levels and there are other diffificult and expensive for many laborafeasible engineering controls be insticulties with biological monitoring. The tories to use and in the typical industuted before reliance could be placed ASARCO proposed urinary arsenic trial setting the problem of sample on work practices. However, OSHA's level cannot be shown to be a safe contamination would exist at such experience has been that engineering level. Thus, employees exposed for lower levels. controls must be coupled with suitable more than 25 years in the lowest uri- FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 RULES AND REGULATIONS 19617 nary arsenic exposure category (exposure, without regard to the use of res- It is clear that respirators cannot sures under 200 µg/liter) did have pirators, will have minimized the pogenerally be considered as the primary excess respiratory cancer mortality tential for over exposure resulting means of employee health protection. (though it is true earlier exposures from poorly fitting respirators and will OSHA has carefully considered all may have been higher). Further, as usually reduce the number of employthese problems and has nonetheless discussed in the occupational health ees who need to wear respirators. concluded that if the permissible expoimplications section, there is a signifi- The final standard clarifies the lansure limit is exceeded then employees cant body of scientific opinion that it guage in the proposal by clearly placmust use the respirators provided. is not possible given present methoding the burden on the employer, for Where engineering controls and work ology to demonstrate a safe level for a proving or disproving feasibility. The practices do not succeed in reducing carcinogen. The limited amount of eviemployer is in the best position to exposure below the permissible expodence ASARCO has submitted is not gather evidence on feasibility in a parsure limit, it becomes necessary to utisufficiently convincing to adopt their ticular workplace. He is most familiar lize respirators to give sufficient approach. with his own production processes and health protection to employees. OSHA also does not believe in many engineering modifications which can In situations where a significant circumstances it is an appropriate be made. Further it is the policy of the number of employees will be wearing compliance strategy to rotate employ- OSHA Act that employers be required respirators for more than a short ees into and out of high exposure to take steps to investigate the feasiperiod of time, the employer is reareas to reduce worker exposures to bility of controls and install them as quired to institute a more elaborate carcinogens. This approach would necessary. respiratory protection program to present the possibility of increasing maximize the effectiveness and minithe' number of workers exposed to (G) RESPIRATORY PROTECTION: mize the discomfort of extended respihigher levels of a carcinogen. If PARAGRAPH (h) rator use. Items to be considered for ASARCO proposes to use engineering The standard requires that respirainclusion in such a program are controls to reduce exposures, then the tors be used only during the time making available a greater variety of ADL cost figures are misleading as period necessary to install or implerespirators for employee use, having a they just indicate monitoring costs. ment feasible engineering and work technician fully trained in respirator The actual cost of the ASARCO stratpractice controls, in operations where use and selection, and organizing the egy will be much nearer the cost of engineering controls are not appropriwork SO that part of the day can be the standard compliance strategy ate such as some maintenance operspent in clean rooms or areas where since a substantial amount of engiations, in work operations in which the TWA limit is not exceeded. The neering controls would have to be insuch controls are not feasible or are employer should also plan to provide stalled. not yet sufficient to reduce exposure respirators with microphones or other The Council on Wage and Price Stato the permissible limit, or in emergencommunication equipment where bility (Ex. 169) and some industry repcies. These restrictions on the use of needed. resentatives (see Ex. 12 for example) respirators are consistent with the re- Respiratory protection also has a suggested a control strategy involving quirements of 29 CFR 1910.1000(e) role during maintenance operations as principal reliance on respiratory proand with good industrial hygiene pracwell as during emergency situations. tection, to reduce the cost of complitice. However the goal of the standard is ance. However, as will be discussed in a Many comments (Exhibit 11, 19, the control of emissions at the source subsequent section, there are many 29G, 29H, 117, 118, 119) cited problems to minimize the need for respirators. difficulties with respiratory protection associated with respirators. Respira- Since it is apparent that respirators as testified by respirator expert Bruce tors are to be considered secondary to may be necessary, an evaluation of res- Held (ATR 227-229) as well as some inthe objective of limiting emissions at pirators for inorganic arsenic use is dustry representatives (Ex. 29H). Bethe source (ATR 229). Proper facial fit necessary. The standard contains two cause of the difficulties in face fit, it is is essential, but due to variations in inrespirator selection tables (Tables I difficult to know whether the respiradividual facial dimensions, as well as and II) so the employer will provide tors actually provide adequate protecfacial hair, scars or growths, is diffithe respirators which afford the tion. Respirators, by interfering with cult to maintain. Fatigue and reduced proper degree of protection based on vision, hearing, and mobility, can efficiency may occur more rapidly the airborne concentration of inorgancause safety problems. Some employamong workers wearing respirators ic arsenic. These tables are principally ees cannot wear respirators because of due to increased breathing resistance, based on the NIOSH recommendation breathing difficulties. Finally, it is not heat stress and reduced vision (ATR made during the September 1976 hearappropriate to place the burden of 228). Safety problems presented by ings (Ex. 146B) and OSHA's expericompliance principally on the employrespirators must be considered. Respience in this and other rulemakings. ee, as would be the case if respiratory rators can limit vision (ATR 228). This However, a significant change has protection were the principal means of can be significant, in smelters, for exbeen made from the NIOSH recomreducing employee exposure. Thereample where physical hazards exist mendations. This principally involves fore, OSHA retains in the standard and the employee's ability to see is impermitting the use of air purifying resthe policy of principal reliance on enportant (ATR 246, Ex. 29G). Speech is pirators with half mask and high effigineering controls and work practices, also limited. Voice transmission ciency filter for protection against except in circumstances where there through a respirator can be difficult, nonvolatile arsenicals including arappears to be no feasible alternative to annoying and fatiguing. Communicasenic trioxide. more substantial reliance on respiration may make the difference between During the September 1976 heartory protection. a safe efficient operation and a hazings, NIOSH (Ex. 146A, 146B, STR 67) Even in situations in which engineerardous operation, especially in dangerrecommended that only chemical caring controls will not succeed in reducous jobs. (ATR 245, Ex. 29G, p. 13). tridge and gas mask respirators be ing exposure levels below the TWA Entanglement of hoses of air respiraused where workers are exposed to inlimit, it is still appropriate to require tors as well as limited mobility due to organic arsenic compounds based on all feasible engineering controls to be hose lengths (ATR 242) are problems theoretical considerations that some installed, even though they would in heavy industrial environments. Selfarsenic compounds may have high have to be supplemented by the use of contained breathing apparatus have vapor pressures. Questions have been respiratory protection. The engineerthe problem of carrying around a raised whether arsenic trioxide has ing controls, by minimizing the expoheavy weight (ATR 242.) significant vapor pressure at ambient FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 19618 RULES AND REGULATIONS temperatures (Ex. 129) and at elevated ide dust. (Ex. 164). For the above reacollapses slightly. Employees should temperatures (Ex. 146, 157). sons, OSHA will continue to allow the be trained to perform this test. To see whether arsenic vapor might use of half-facepieces for protection The standard requires a qualitative be eluding capture by high efficiency against inorganic arsenic particulate. fit test at the time of initial fitting filters ASARCO conducted a respira- In those situations where arsenic and semiannually thereafter. If the tor experiment (Ex. 160B No. 2). Rescompounds do have high vapor presparticulate filters can be replaced with pirator testing was performed by sussures, the NIOSH recommendations chemical cartridges, isoamyl acetate pending the respirators from a metal for such a situation are followed. can be used to qualitatively test facebar supported by two ring stands. Table II of the standard specifies the piece fit. If the employee can smell None of the test equipment was worn respirators which must be worn to prethe isoamyl acetate while wearing the by a worker. To simulate a good fit vent excess exposure to arsenicals respirator it can be concluded that the against a worker's face, each respirawith high vapor pressures. Two chemiparticular respirator will not provide tor backing was covered with at least cals which do have significant vapor suitable protection. four thicknesses of plastic wrap. Two pressure are arsenic trichloride and ar- The standard requires that employsampling trains were used. One emsenic phosphide. ers with more than 20 employees wearployed a probe located inside the During the April 1975 hearing, ing respirators provide a quantitative sealed respirator followed by a Bruce Held (ATR 231-236) recomfit test at the time of initial fitting preweighed millipore filter. The millimended changes to the proposed respiand semiannually thereafter. In a pore filter was backed up by impingers rator selection table in paragraph quantitative fit test the level of leakcontaining potassium permanganate (g)(2) of the proposal (Ex. 2A). Mr. age and degree of protection is specifior sodium hydroxide. A personal moni- Held stated that "constant flow" cally measured by instrumentation. tor (10 to 20 liters per minute flow should be deleted from (g)(2)(i)(B), These tests are more accurate and prorate) was used as the suction source. "pressure demand" changed to vide greater assurance that the respi- The second sampling train consisted of "demand" (g)(2)(iv)(A) and (g)(2) rator is providing proper protection. a probe, millipore filter, giant Green- (v)(B) to "demand". We have adopted One type of quantitative fit test inburg-Smith impinger, dry gas meter these recommendations using more volves using a simple hood, sodium and pump (10-20 liters per minute recent terminology. The protection chloride vapor, and automated instruflow rate). Efficiencies of the high effactors used in the table reflect the mentation. At least one such device is ficiency filters averaged better than 99 factors found in the August 2, 1976 commercially available at less than percent for protection against arsenic joint OSHA/NIOSH Standard Com- $10,000. These tests can be performed (Ex. 160B, No., 8, 9). Table 1 (Ex. pletion Program Respirator Decision rapidly (10 to 20 minutes) and are rela- 160B) contains the summary of ASAR- Logic (Ex. 146C). tively easy to perform. This require- CO's results. It is noteworthy that the There are numerous factors which ment is limited to employers with highest vapor and or sub/micron conaffect the performance of air purifymore than 20 workers wearing respiracentration was 0.66 µg/m³ both inside ing respirators. These include the tors. At present, organizations are not and outside the respirator indicating filter material and the fit of the faceavailable to provide these testing serthat any vapor problem is minimal in piece on the wearer. Also important is vices. Therefore the requirement/ is comparison to the permissible expowearer acceptance and training. limited to employers with greatest sure limit. Thus, air purifying respira- Proper fit of the respirator is critineed for testing and for whom it is tors with high efficiency filters will be cal. As a negative pressure is created reasonable to acquire the equipment. allowed in the final standard except within the facepiece when the wearer However, OSHA recommends that all for inorganic arsenic compounds with breathes, unfiltered air may enter the employers who have access to quantidemonstrated significant vapor presfacepiece if gaps exist. Obtaining a tative fit testing make use of such fasure. proper fit on each employee may recilities for employees who regularly Arsenic trioxide as well as some quire the employer to provide two or wear respirators. There was no specific other arsenicals, are skin irritants and three different mask styles. requirement for quantitative fit tests can cause skin irritation where the fa- The employee must be properly in the proposal. But subsequent develcepiece of the respirators comes in trained to wear the respirator, to know opments of equipment to make them contact with the worker's face. Bewhy the respirator is needed and to relatively easy to carry out and the cause they found no documented understand the limitations of the resgreater assurance of proper protection study indicating a threshold for eye irpirator. An understanding of the they provide, make it appropriate that ritation and because they judged there hazard involved is necessary to enable they be required for employers with was an increased potential for skin irthe employee to take steps for his or significant numbers of employees on ritation using half-masks, NIOSH recher own protection. The respiratory respirators. ommended that full facepiece respiraprotection program implemented by The standard makes the wearing of tors be the minimal protection against the employer must conform to the respirators voluntary, at the option of particulate arsenic (STR 77-8). The program set forth in 29 CFR 1910.134. the employee until December 31, 1979 record does not support these points. This contains basic requirements for except when employees are exposed in ASARCO has noted that complaints proper selection, use, cleaning, and excess of 50 µg/m³. While exposures in of eye irritation have been relatively maintenance of respirators. excess of the permissible exposure few, mostly having arisen from gross The employer must check to see limit do constitute a hazard, OSHA beaccidental exposure to dust or to imthat the employees' respirators fit lieves that it is necessary to mitigate paction of large particles on the eye properly and that leakage is at a minisome of the problems associated with (Ex. 164). Safety glasses which are mum. A rapid simple fit test can be respirator use and to permit time for now worn by smelter workers, have performed at the start of each shift by educating and training employees in been noted to protect such smelter each employee wearing a negative the need for and use of respirators. workers, except in rare occasions (Ex. pressure respirator. This test can be During the voluntary period, control 164). Finally, the use of a full faceeither a positive pressure test, in measures, such as installation of engipiece would result in more skin conwhich the exhalation valve is closed neering controls and improved work tact with the rubber or plastic of the and in which the wearer exhales into practices can be implemented. These facepiece resulting in more discomfort the facepiece to produce a positive controls will result in an improved and sweating. The increased contact pressure, or a negative pressure test, work environment which will substanand increased sweating has resulted in in which the inlet is closed and the tially reduce the number of employees more skin irritation from arsenic trioxwearer inhales so that the facepiece required to wear respirators. The vol- FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 19620 RULES AND REGULATIONS Certain trivalent arsenicals (arsenic pirator use, suitable precautions need ered at length, OSHA has determined trioxide, sodium arsenite, potassium to be taken to avoid significant skin that 30 days is an appropriate cut-off arsenite, copper acetoarsenite) have contact. point for inclusion in medical examibeen implicated as systemic carcino- Arsenic trichloride is rapidly abnations. gens. Some case reports based on longsorbed through the skin and creates a The final standard includes a reterm administration of medicinals conserious acute toxicity hazard. In consequirement that all employees who taining potassium and sodium arsenite quence all skin and eye contact is promay have been exposed above the (Exhibits 180 and 101) and occupationhibited. Where feasible arsenic trichloaction level for 10 or more years must al exposure to sodium arsenite and ride should only be utilized in closed be provided with medical examinacopper acetoarsenite (Paris Green) systems with suitable backup controls tions although they are no longer ex- (see sec. IV C of this preamble) have in case of system breakdowns. Where posed above the action level. The lanimplicated ingestion of these chemisuch a system is not feasible, the emguage in the proposal was unclear on cals as carcinogens. A high incidence ployer is required to provide impervithis point. Medical examinations are of skin cancer has been reported in ous protective clothing and suitable mandated for this group because they several populations exposed to high respirators. represent a potentially higher risk concentrations of arsenic in drinking group. Arsenic exposures have been rewater (Exhibit 180 pp. 299-301, Exhib- J. MEDICAL SURVEILLANCE: PARAGRAPH (N) duced since the 1950's in most smelters it 58). In addition, OSHA believes as a The standard requires each employand chemical manufacturers. general matter that efforts must be er to institute a medical surveillance Long-term employees who have extaken to minimize exposure to carcinoprogram for all employees who are exposures now or in the near future gens by all exposure routes including posed above the action level for at below the action level, but have had ingestion. least 30 days per year and for employexposure above the action level now or The proposal did not include a reees who have been exposed to levels in the recent past, are quite likely to quirement for lunchrooms with filabove the action level for more than have had substantially greater expotered air though it did prohibit eating 10 years who are no longer exposed sures in the more distant past. Dr. in regulated areas. Union representaabove the action level. The record, in- Brooks testified on this point (STR tives recommended that such lunchcluding recommendations from 45-52) and the epidemiological studies rooms be provided (Exhibits 22, 30, NIOSH in its updated Criteria Docuindicate that risk increases with both 121). The suggestion has been adopted ment (Exhibit 99), clearly indicates degree and duration of exposure. because such facilities are needed to that a medical surveillance program is The medical examination required is provide a suitable place, relatively free appropriate in dealing with the probprincipally based on the known utility from contamination to inorganic arlem of employee exposure to inorganic of x-ray and sputum cytology as senic, for workers working in regulated arsenic. Section 6(b)(7) of the Act proscreening tests for respiratory cancer. areas to eat. In addition, suitable vides that: Two portions of the proposed medilunchroom facilities will provide an incal surveillance protocol have been deducement for employees not to eat in where appropriate, any such standleted. These are palpation of superfiregulated areas. As the risk of ingesard promulgated under subsection 6(b) shall cial lymph nodes and, a complete prescribe the type and frequency of medical tion is highest in Junchrooms, someexaminations or other tests which shall be blood count. As noted previously, lymwhat more elaborate regulations for made available, by the employer or at his phatic and hematopoietic cancer extheir design are included. Since the cost, to employees exposed to such employcesses have only been observed in risk of ingestion is less below 10 µg/m³, ment related hazards in order to most effecworker populations in the Ott and the standard requires those facilities tively determine whether the health of such Baetjer studies (in which workers were only for employees exposed above that employees is adversely affected by such exexposed to sodium arsenite, potassium level rather than at the 2 µg/m³ level posure. arsenite, and copper acetoarsenite). As of the proposal. This change will also The proposed standard (Exhibit 2a, p. OSHA is not aware of groups of workreduce the burden on the employer. 3400), provided that medical examinaers in this category at the present Eye wash requirements contained in tions should be given to all employees time, it is not appropriate to require the proposal have been deleted. There exposed above the action level. The these tests generally. These tests may appear to be few locations or arsenifinal standard also requires medical be given at the discretion of the examcals for which such facilities might be surveillance for all employees exposed ining physician and would be adviseaneeded to prevent serious eye injury. above the action level (5 µg/m³. Alble if an employee has been exposed to The standard requires employers to though the level of exposure which those chemicals. prevent employee skin or eye contact triggers medical surveillance has Neither the proposal nor the final with liquid or particulate inorganic archanged, the rationale remains the standard requires that urinary arsenic senic which is likely to cause skin or same. determinations be a mandatory part of eye irritation. As discussed in the Some employees may be assigned to the medical surveillance protocal. The health effects section, some arsenicals work areas where they may be excorrelation of urinary arsenic levels cause skin irritation, and keratosis was posed to inorganic arsenic above the and airborne arsenic exposure is fairly a condition observed among workers action level on a temporary or short weak (r=0.528). Urinary arsenic levels exposed to substantial amounts of arterm basis, e.g. during vaction periods vary considerably from individual to senic. These keratoses also seem to be or certain types of repair work. Thereindividual and time to time. Accordrelated to various forms of cancer fore a cut-off point for the required ingly, we feel that the use of urinary which subsequently developed. medical surveillance program is arsenic determination to supplement Reducing the airborne exposure needed since it would not be approprimonitoring of airborne levels of arbelow the permissible exposure limit ate to provide medical surveillance for senic should be left to the discretion should eliminate skin irritation from every employee regardless of duration of the individual company or physiexposure to arsenic. In areas where exof exposure. It is important that the cian. posures are somewhat over the permistime period selected be sufficiently in- All examinations and procedures are sible exposure limit, supplying and clusive without being administratively required to be performed by or under using appropriate clean protective impracticable. The arsenic record did the supervision of a licensed physician clothing and gloves as required by the not specifically address this point. and provided without cost to the emstandard should prevent skin irrita- Consistent with OSHA's experience ployee. Clearly, a licensed physician is tion. In areas of higher exposure, such gained in the coke oven emissions prothe appropriate person to be supervisas arsenic kitchens, in addition to resceedings where the matter was considing and evaluating a medical examina- FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 RULES AND REGULATIONS 19619 untary nature of respirator use prior ing Respirator (PAPR). In addition, The proposal required the employer to December 31, 1979 does not reduce other types are under development. It provide and clean daily protective the employer's obligation to train emis OSHA's experience that in many clothing. The final standard reduces ployees in the proper use of the respicircumstances, PAPR's are more comthe frequency to weekly, except where rators and to make the appropriate fortable to. wear and provide better there is a significant probability of respirators available. Indeed, since the protection. They are light, under posiskin irritation because of exposures employee is being granted a greater retive pressure and do not require a above 100 µg/m³ such as in some locasponsibility for his or her own protectight facial fit thereby minimizing irritions in the ASARCO, Tacoma arsenic tion, special attention must be given to tation and breathing resistance. plant. The original requirement was the training program so the employee Except in cold weather, the air stream designed to reduce skin irritation. can make an informed choice. provided makes them more comfort- However, at levels approaching 10 µg/ The proposal required immediate able. They have a higher protection m³, skin irritation is unlikely. Accorduse of respirators whenever employees factor than negative pressure respiraingly, the cleaning requirement is were exposed in excess of the TWA tors since face fit is not a crucial changed to weekly to reduce the limit. This would have essentially refactor. While they are more expensive, burden on the employer. At levels quired the wearing of respirators by a they interfere with work far less than where skin irritation is likely, or at large number of workers in some fanegative pressure respirators. Therelower levels where skin irritation is OCcilities on the effective date of the fore, OSHA believes it appropriate curring, the daily cleaning requirestandard. The transition period prothat employees have the option of ment is retained. vided by the final standard will alleviwearing PAPR's. Consequently, the The final standard clarifies that the ate this burden and permit more time standard gives the employee the obligation is on the employer to profor training and implementation of a option of wearing PAPR's in approprivide protective equipment at no cost to respirator program. The employer is ate circumstances after December 1, the employee. In this way the employrequired to provide respirators for em- 1978. The employer must also supply a er is in the best position to provide the ployees exposed between 10 and 50 µg/ combination dust filter with a gas sorcorrect type of equipment and keep it m³ as soon as possible but with an outbent where there will be exposure to in repair. Also, as the employer has side limit of December 1, 1978 to allow gases (such as sulfur dioxide) over the permitted exposures to exceed the pertime which may be needed to purchase relevant limit for that gas some of the missible exposure limits the obligation and receive a sufficient number of restime. This will be the case some of the properly rests on the employer. The pirators. There are fewer employees time in smelters. If over-exposures to cost of necessary equipment has been exposed between 50 µg/m³ and 500 µg/ gases are relatively continuous, included in the various economic anal- m3 and those employees face more PAPR's would not provide suitable yses performed. severe risks. Therefore respirators protection. The standard provides that the emmust be supplied as soon as possible ployer ensure that all protective clothand no later than October 1, 1978 for H. PROTECTIVE CLOTHING AND EQUIPMENT ing is removed at the end of each work those employees. Respiratory use is PARAGRAPH (j) shift only in change rooms, and that now required for employees exposed The standard requires the employer the clothing that is to be laundered, over 500 µg/m³ and therefore respiracleaned, or disposed of be placed in a to provide and assure that employees tors continue to be required from the closable container in the change room. use protective clothing and equipment effective date of this standard. The purpose in requiring such a conwhere the employee is exposed above The standard requires that employtainer is to prevent the contaminants the permissible exposure limits to preees wearing air-purifying respirators on the clothing from coming into convent contamination of street clothing, be permitted to replace the respiratact with an individual handling the to prevent skin and eye irritation and tor's filter whenever they detect a sigcontainer or being released in the to prevent skin absorption of arsenic change room. Since the container is to nificant increase in breathing resistrichloride. The employer is responsitance. When the filter becomes loaded, be located in the change room, it is apble for cleaning and replacing the propriate to limit the removal of conthe movement of air through the filter clothing as necessary. Specifically, the taminated clothing to that area. becomes restricted forcing the employemployer is to provide coveralls or Finally, the standard requires the ee to breathe harder to overcome this other full body clothing. gloves, and employer to inform those who handle resistance. The wearing of the respirashoes. The employer must also provide the contaminated articles of the potor becomes increasingly more uncomeye protection and other equipment, tentially harmful effects of exposure fortable and it may not be used as a when necessary to prevent skin or eye to inorganic arsenic. This provision is result. To aid in the minimizing of the irritation. designed to make clear the need to use discomfort of wearing a respirator and The final standard makes a number proper care in handling of the conto keep the respirator working effiof changes from the proposal to retaminated articles. ciently the employee must be allowed spond to the comments, to clarify the to change filters when the need arises. language and to utilize the experience I. HYGIENE FACILITIES AND PRACTICES: The wearing of a respirator in an ardeveloped in the Coke Oven Emissions PARAGRAPH (M) senical atmosphere can result in skin proceeding. The clothing is to be sup- The standard requires that the emirritation as the dust may accumulate plied to employees exposed above the ployer provide clean and suitable around the facepiece seal. To prevent 10 µg/m³ level. It is necessary that change room facilities, lavatories, this irritation and to minimize the disprotective clothing and shoes be reshowers, and lunchrooms for those comfort of respirator use, employees quired to prevent contamination of employees working in regulated areas. must be allowed to periodically wash the employees' street clothing and One purpose of these requirements is their faces and respirator facepieces in shoes, so that exposure is not exto prevent exposure beyond the work order to remove the accumulation of tended beyond the work day. At expoday to the employee. Another purpose inorganic arsenic. sures lower than the PEL, it is less is to reduce the likelihood of skin irri- It will be necessary for some produclikely that clothing will become sigtation resulting from skin contact with tion employees in some smelters to nificantly contaminated with inorganinorganic arsenic. Both of these reawear respirators for a substantial peric arsenic. sons have been discussed in more centage of the day for a number of Impervious protective clothing is redetail in the previous section on Proyears. Subsequent to the arsenic proquired for those workers working with tective Clothing and Equipment. A posal and hearings, NIOSH has certiarsenic trichloride, because it can be third purpose is to prevent the ingesfied a lightweight Powered Air Purifyrapidly absorbed through the skin. tion of inorganic arsenic. FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 RULES AND REGULATIONS 19621 tion. However, certain parts of the re- Comments received from Dr. Dahlment. This was not included in the quired exam do not necessarily require gren (Exhibit 137-12) and Health Reproposal. It is believed necessary to the physician's expertise and may be search Group (Exhibit 137-8), and tesinform the employee to the extent conducted by another person under timony by Dr. Brooks, a noted expert possible if the condition of his health the supervision of the physician. in the field (STR 45-52), as well as by has been affected during the period of The proposed standard included a NIOSH (Exhibit 146) were in favor of employment. requirement that all medical examinarequiring sputum cytology. Comments The employer is required to provide tions be given during the employees' from the Motor Vehicle Manufacturthe physician with certain informanormal working hours. The final ers' Association (Exhibit 137-9) and tion. The employer is also required to standard does not include the require- Dr. Clark Cooper (Exhibit 137-7) were obtain a written opinion from the exment because it may be impractical for opposed. Anaconda submitted prelimiamining physician containing: the shift workers or less convenient for nary results of a study of sputum cyphysician's opinion as to whether the employee or employer. However the tology among its workers (Exhibit employee has any detected medical employer is obligated to pay for the 165B Appendix E, STR 600-601) which conditions which would place the emtime spent taking the medical examicast doubt on its usefulness. ASARCO ployee at increased risk of material imnation if it is taken outside normal recommended that sputum cytology pairment of health from exposure to working hours and the exam must be be included on a trial basis (Exhibit inorganic arsenic; the results of the given at a reasonable time and place. 111-3). medical examination; any recommend- It is necessary that exams be conve- Based on the information received, ed limitations upon the employee's exnient and without loss to the employ- OSHA believes it appropriate to inposure to inorganic arsenic and upon ee to assure that they are taken. clude sputum cytology in the medical the use of protective clothing and The standard provides that a work surveillance protocol. With the develequipment such as respirators; and a history, medical history and medical opment of the fiberoptic bronchostatement that the employee has been examination be performed at the time scope, sputum cytology has become an informed by the physician of any of initial assignment to areas where effective tool for early detection of medical conditions which require furexposure exceeds the action level or respiratory cancer among a higher risk ther examination or treatment. This by December 1, 1978, for employees population such as workers exposed to written opinion must not reveal specifexposed above the action level at the inorganic arsenic. (Exhibit 140, 141A). ic findings or diagnoses unrelated to effective date of the standard. The Used in conjunction with X-rays, occupational exposure, and a copy of purposes of this requirement are to OSHA is hopeful that such early dethe opinion must be provided to the make an initial assessment of the tection will result in prolonged life for affected employee. health of each employee and to estabthose discovered to have respiratory The purpose in requiring the examlish a baseline health condition cancer. X-rays and sputum cytology ining physician to supply the employagainst which changes in an employappear to be complementary, one er with a written opinion containing ee's health may be compared. The probeing more a powerful tool for detecthe above mentioned analyses is to posed standard (Exhibit 2a, 40 FR tion in the peripheral airways while provide the employer with a medical 3401), and Criteria Document (Exhibit the other is for the central airways. basis to aid in the determination of 99, p. I-2) all contained requirements for an initial or preplacement exam. (Exhibit 140, 141A, STR 45-52). initial placement and ability to use A nasal examination is required beprotective clothing and equipment of The history has been expanded slightemployees. Requiring that opinion be ly from the proposal to include inforcause employees with significant expoin written form will serve as an objecmation on smoking because of its relsures to inorganic arsenic are subject tive check that employers have actualevance to increased respiratory cancer to perforation of the nasal septum. A ly had the benefit of this information risk. skin examination is also required. in making these determinations. Like- The various tests that comprise the Such an examination will detect gross wise, the requirement that the emmedical exam are designed to be used overexposures to arsenic. Such expoployee be provided with a copy of the in an initial assessment of an employsure is rare now. However, the examiphysician's written opinion will insure ee's health and to detect changes in nation can be quickly and simply perthat the employee is informed of the health which may occur. The value of formed and therefore has been includresults of the medical exam and may each of the specified examinations is ed. take any appropriate action. The purdescribed below. The standard provides for semiannupose in requiring that specific findings A 14 in. by 17 in. X-ray is a screening al examinations for employees exor diagnoses unrelated to occupational test of proven value in the detection of posed over the action level who are 45 exposure not be included in the writlung cancer. The International Labour years of age or older, and for employten opinion is to encourage employees Office UICC/Cincinnati (ILO U/C) ees who have been exposed for 10 or to submit to medical examination by rating is useful in obtaining uniform more years above 5 µg/m³. All other removing the fear that employers may quality in the reading of X-rays. employees working in regulated areas find out information about their phys- Sputum cytology is required in cerare to be provided with medical examiical condition that has no relation to tain circumstances by the* final standnations on an annual basis and their occupational exposures. ard though was only recommended examination need not include sputum The proposal included a provision in the proposal. (See Appendix C to cytology except for the initial examithat the physician state whether expothe proposal). The proposal did not nation. ASARCO recommended a less sure to inorganic arsenic would directmandate sputum cytology on the basis frequent examination. The frequency ly or indirectly aggravate any medical that it should be optional depending in the final standard is consistent with condition. This provision has been deon the opinion of the examining phythe proposal, Dr. Brook's testimony leted from the standard for two reasician. Subsequent information re- (ATR 45-52) and OSHA's experience sons: It is vague, in that it is unclear ceived during the coke ovens proceedduring the coke oven emissions prowhat "aggravate" means. Secondly, it ing indicated that sputum cytology ceeding. The more frequent and more adds nothing to the requirement to dewould be of value. The issue was raised extensive examinations are specified termine whether an employee has any more fully in the FEDERAL REGISTER for the higher risk population as disdetected medical conditions which notice of July 16, 1976 (41 FR 29425) cussed above. place the employee at increased risk of which specifically requested comments Employers are required to make a material impairment of health from on this issue and included it as one medical examination available to an exposure to inorganic arsenic. issue to be considered in the Septememployee who has not had one within The proposed standard included a ber 1976 hearing. six months of termination of employprovision prohibiting the exposure of FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 19622 RULES AND REGULATIONS an employee to inorganic arsenic if the of rate retention will also involve con- The employer is also required to proemployee would be placed at increased sideration of the mandatory removal vide, upon request, all materials relatrisk of material impairment to his or question. ing to the training program to the Asher health from such exposure (Exsistant Secretary and the Director. hibit 2A, 40 FR 3402). The proposal (K) EMPLOYEE INFORMATION AND This is intended to provide an objecdid not include any provision requiring TRAINING: PARAGRAPH (o) tive check of compliance with the conthe transfer of that employee to an- The final standard requires the emtent requirements of the standard. It other job, or requiring that the employer to provide a training program should be noted that the recordkeepployee be guaranteed his earlier rate for employees exposed above the ing requirement regarding the training of pay. action level or for whom there is a posprogram which had been included in In this proceeding, representatives sibility of skin or eye irritation from the proposal has not been retained in of unions indicated their great concern contact with inorganic arsenic. the standard to reduce the recordkeepregarding any requirement for the The need to train employees was ing burden. This places greater relimandatory removal of employees beagreed upon by virtually all of the parance on access to training materials as cause of increased risk, in the absence ticipants in the rulemaking proceed- a check to ensure that employees are of a medical removal protection or ing, and a training requirement was inbeing properly trained. rate retention, right for employees so cluded in the Criteria Document (Ex. removed (Exhibit 22, 103). The major 99, p. 7) and the proposed standard. L. SIGNS AND LABELS: PARAGRAPH (p) argument presented was that in the The proposal required training in all The final standard requires that regabsence of a medical removal proteclocations where any inorganic arsenic ulated areas be sign posted stating: tion provision, such a requirement was released or handled. However, in- "Danger, Inorganic Arsenic Present, would constitute a major disincentive organic arsenic is naturally present at Cancer Hazard, Authorized Personnel to employees to submit to physical exvery low levels in some substances Only, No Smoking or Eating, Respiraaminations because they would fear where there is little possibility of its tor Required". It also requires labeling that an adverse medical opinion could release. The benefit in requiring trainof containers of inorganic arsenicals, result in loss of employment. As a ing in these circumstances did not except when the arsenic is bound in result, the purpose of the medical surseem significant and the scope of the such a manner as to make unlikely the veillance requirements would be undetraining provision has been narrowed possibility of exposure to inorganic artermined and early detection of illness accordingly. senic. The labels must state, "Caution, would, too often, not occur. It was also The training program is required to Contains Inorganic Arsenic, Cancer suggested that the absence of a medibe completed by October 1, 1978, for Hazard, Harmful if Inhaled or Swalcal removal protection provision creemployees initially covered by the lowed, Use only with Adequate Ventiates a dilemma antithetical to the purstandard and at the time of initial aslation or Respiratory Protection". poses of the Act-namely, the employsignment to areas where there is possi- It is important, and section 6(b)(7) ee's need to choose between continubility of exposure over the action level of the Act requires, that appropriate ing to work but risking his life by conor skin irritation otherwise. OSHA beforms of warning, as necessary, /be tinuing to do so, and protecting his lieves that it is important to train emused to apprise employees of the hazhealth, but losing his job. ployees as soon as possible, consistent ards to which they are exposed in the The Agency agrees that the apwith developing suitable materials, in course of their employment. OSHA beproach taken in the proposed standard order to maximize the benefits of the lieves, as a matter of policy, that emconfronts the employee with a diffitraining program, and has acted acployees should be given the opportunicult choice and we are sympathetic to cordingly. ty to make informed decisions on the concerns reflected in the unions' The standard requires that the whether to work at a job under particposition on this issue. However, we betraining program be provided at least ular working conditions. Furthermore, lieve that the present record does not annually except that it must be prowhen the control of potential safety contain sufficient evidence on the provided quarterly for those employees and health problems involves the copriety, scope and implications of manwho have optional use of respirators operation of employees, the success of datory transfer and rate retention reuntil December 31, 1979. OSHA besuch a program is highly dependent quirement so as to constitute an adelieves that an annual training program upon the worker's understanding of is both necessary and sufficient to quate basis for the incorporation of the hazards attendant to that job. remind the employee of the hazard. such a provision in the standard. In light of the serious nature of the Quarterly training is required for em- While we are not providing for medihazard of exposure to inorganic arployees who have optional use of rescal removal protection in the standard, pirators so that those employees will senic, OSHA believes that sign posting we are convinced that further explorabe in a position to make informed is needed as well as periodic training tion of this issue is necessary in order choices regarding the use of respirato adequately inform employees of the to deal in considerably more depth tory protection. cancer hazard. The appearance of the with the numerous issues raised by The content of the training program phrase "Cancer Hazard" on the warnsuch a provision. OSHA has held a is intended to apprise the employees ing sign will serve as an objective hearing specifically in regard to mediof (1) the hazards to which they are check on whether employees are actucal removal protection for employees exposed; (2) the necessary steps to ally being informed of this hazard. It exposed to lead. OSHA is now considprotect themselves, including minimizis a reasonable precaution to discourering the record developed in that ing exposure, respiratory protection age unnecessary entry of occasional hearing. Based on the experience and medical surveillance; (3) their role visitors to regulated areas. Also, the gained in that proceeding OSHA will in reducing emissions; and (4) their warning signs will inform all employconsider whether medical removal prorights under this standard. ees entering regulated areas of the tection should be proposed for em- The employer is required to make a need to utilize respirators and other ployees exposed to other substances. copy of the standard and its appenprotective equipment which the em- In the meantime, OSHA has decided dixes available to affected employees. ployer is to provide. to delete the mandatory removal pro- This requirement, in combination with A number of comments were made vision. In our view, the issue of mandathe review provided for as part of the that such signs would cause unnecestory removal is closely related to the training program, is intended to sary alarm (Exs. 3E, 3T, 27). Given the issue of rate retention and neither ensure that employees understand evidence of the carcinogenicity of inorshould be addressed in the present their rights and duties under this ganic arsenic, a strong warning is necstandard. The Agency's further study standard. essary and the word "Hazard" has in FEDERAL REGISTER, VOL. 43, NO. 88-FRIDAY, MAY 5, 1978 RULES AND REGULATIONS 19623 consequence been substituted for the keeping such records, but objected to enforcement and research purposes. ambiguous term, "Suspect Agent." Adthe length of the record retention The employees or their representaditionally, the phrases "Authorized period. It is necessary to keep these tives need access to exposure records Personnel Only" and "No Smoking or records for such extended periods of because they help the employees de- Eating" and "Respirator Required" time because of the long latency peritermine the effectiveness of the emrelate directly to requirements in the ods commonly observed for carcinoployers' exposure abatement program. standard which limit access and activigens. Cancer is often not detected The physician needs access to medical ties within regulated areas. (See disuntil 20 or more years after onset of records for diagnostic purposes. The cussions of Regulated Area and of Hyexposure. The extended retention transfer provisions are unchanged giene Facilities and Practices.) period is therefore needed for two purexcept that NIOSH is to be notified at All shipping and storage containers poses. Diagnosis of disease in employthe expiration of the retention period of inorganic arsenic compounds and ees is assisted by having exposure data so it can determine if the records are products containing it are required to as well as the results of the medical still needed for research purposes. be labeled with a warning of the exams even many years in the past. cancer hazard and the precautions to The original x-ray and cytology slide N. EMERGENCIES be taken. This is so employees hanand those in the recent past are redling the materials will treat them The final standard, unlike the-proquired to provide a baseline as well as. with care and take suitable precauposal, includes no specific paragraph a guide to the progression of symptions to avoid inhalation. It is necescovering emergency situations. OSHA toms. It is necessary to retain monitorsary to warn employees to take pregenerally includes specific provisions ing and medical surveillance data for cautions in case of spills or broken on emergencies for chemicals prothe same period because the data has containers. duced in high pressure processes, to be considered together. The second The proposal did not include any exwhere there is the possibility of explopurpose for retaining records for 40 ception to this provision. Comments sions or other massive release of the years is so that it will be possible at were received stating that the inorgansubstance, or where there are acute some future date to review the adeic arsenic present in certain products toxicity dangers. quacy of the standard. was bound in such a manner as to In non-ferrous metal smelters these The final standard makes a number make unlikely the possibility of expodangers appear unlikely. Arsenic is not of changes from the proposal. Some of sure to inorganic arsenic. An example generally subject to explosion. Furof this is the light emitting diode (Exthese reduce the recordkeeping ther the arsenic is usually present as hibit 137-4). In such circumstances, a burden. The respirator recordkeeping only a small percentage in the materihas been simplified and the retention warning label is inappropriate because al stream, making unlikely acute toxicthe hazard does not exist. Therefore, period made the same length as for exity episodes as a result of equipment the final standard excludes from the posure measurements so that exposure breakdown. labeling requirements, those containlevels can be assessed. Provisions in Therefore, OSHA has decided to iners or products in which arsenic is the proposal requiring records of emclude no specific regulatory paragraph bound in such a manner to make unployee training and regulated area roson emergencies. However, it should be likely airborne exposure. ters have not been retained in the noted that the employer is required by Exposures are not unlikely if dropfinal standard. These two records were the respirator section to have availaping, breaking or ordinarily negligent deleted because there appeared to be ble and provide respirators when a handling will likely result in overexpolittle benefit in their retention. Trainbreakdown of equipment or accident sure. ing materials can be inspected when leads to high exposures. Further, as a necessary to determine compliance. matter of proper industrial practice, M. RECORDKEEPING: PARAGRAPH (q) The roster duplicated data required to OSHA expects employers handling or