The American Industrial Hygiene Association® (AIHA) earlier this month filed comments for the Occupational Safety and Health Administration's Request for Information (RFI) on Chemical Management and Permissible Exposure Limits (PELs). Published in the Federal Register on October 10, 2014, Volume 79, number 197, page 61383, the RFI outlines potential revisions to OSHA's current risk and feasibility assessment approaches and requests additional information regarding chemical management for the workplace that may be more efficient, while still protecting worker health and safety.

AIHA's submission to OSHA includes a copy of the AIHA white paper "Permissible Exposure Limits (PELs)" and comments compiled from AIHA Volunteer Groups. The white paper includes the following recommendations:

• OSHA should develop a peer-reviewed guideline for the derivation of PELs. AIHA believes that PELs must be based on the best scientific information available and must include a well-documented, critical evaluation of the supporting information. AIHA also believes that appropriate uncertainty factors must be applied to compensate for the inherent uncertainties in the existing data and extrapolation to human populations.
• OSHA should seek whatever resources or legislative changes are needed to allow the updating of all existing PELs to current science and to set such new PELs as are necessary to protect worker health. In the meantime, OSHA should select chemicals for PELs based on scientific principles and specific criteria developed with all stakeholders.
• PELs should be consistent across occupational populations and should be accepted by other federal agencies when the goal is protecting occupational health. 

"Permissible Exposure Limits (PELs)" was originally adopted by AIHA in 1998, updated in 2002 and 2009, and has been redefined and readopted this year.

Click here to read the full white paper and list of submitted comments.