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<strong;From:</strong;&nbsp;James Repace [mailto:[email protected]]&nbsp;
<strong;Sent:</strong;&nbsp;Friday, September 21, 2012 10:22 AM
<strong;To:</strong;&nbsp;Glantz, Stanton A
<strong;Subject:</strong;&nbsp;Re: OSHA PEL is not the appropriate standard for involuntary exposure to e-cig emissions
Stan you are absolutely right. &nbsp;Further to the point OSHA PELs are designed by law to be stringent enough to avoid workers being overcome during a workshift, but explicitly do not guarantee that long term exposure will not cause health effects. &nbsp;Moreover, they are designed for a healthy workforce, not infants, the elderly, or those whose health is compromised. &nbsp;Finally, the OSH Act has an explicit cost-benefit test which unlike section 112 of the Clean Air Act, does not permit regulation of an occupational pollutant below the level that it is possible for the affected industry to economically meet. &nbsp;As an example: &nbsp;OSHA's PEL for 8-h occupational exposure to respirable dust is 5000 ug/m3, corresponding to a 1667 ug/m3 24 hr ave., while EPA's 24-h PM2.5 standard is 35 ug/m3, designed to protect sensitive groups. &nbsp;So the PEL argument is bogus. &nbsp;Furthermore, for 4-aminobiphenyl and beta naphylamine, both potent bladder carcinogens with short latency periods -- a decade or less -- there is no permissible exposure for workers. &nbsp; All three pollutants occur in secondhand smoke, although 2 of the 3 perhaps not in eCigs. &nbsp;Jim
James Repace, MSc.&nbsp;Biophysicist;&nbsp;Repace&nbsp;Associates, Inc.&nbsp;Secondhand Smoke&nbsp;Consultants. &nbsp;6701&nbsp;Felicia Lane &nbsp; &nbsp;Bowie,&nbsp;MD 20720 phone 1-301-262-9131&nbsp;fax 1-301-262-3865&nbsp;email:&nbsp;<mailto:[email protected]";;;&nbsp;website:&nbsp;<";;.

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