Industry representatives and worker groups alike praised the 93-page document as a compilation of helpful procedures, many of which have not been widely adopted. But industry representatives also contended that the initiative was most significant for what it did not produce – a federal standard turning the recommendations into requirements.
There was certainly some desire that this process should lead to a standard, said Castrols John Howell, a member of the Metalworking Standards Advisory Committee, which provided input during drafting of the manual. If this represents the culmination of the process, if it goes no further than this, then I feel satisfaction that it did not result in another regulation.
The manual, which draws heavily from a guide written by Organization Resources Counselors Inc., provides general information about metalworking fluids and recommends a systems management approach to control levels of worker exposure to fluids. Suggested measures range from machine enclosure to ventilation to use of personal protective equipment.
The guide urges employers to establish fluid management programs that are overseen by individuals versed in metalworking chemistry and that test and track data on fluids used.
It also recommends air sampling to monitor exposure levels. Rather than advising particular limits, it cites those mandated by OSHA, as well as others recommended by the National Institute for Occupational Safety and Health, the American Conference of Governmental Hygienists and the advisory committee.
Finally, the manual recommends monitoring exposed employees to identify early evidence of respiratory impairment or skin disease.
David Burch, an advisory committee member representing the Precision Machined Products Association, said he believed that some of the recommendations monitoring employee medical conditions went overboard but that the manual included a great deal of helpful information, including many suggestions that were practical and not costly.
Its a good document, Burch said. Now I want to know what kind of marketing they are going to do to let people know about it.
Howell noted that a majority of the advisory committee, which included labor union representatives and public health officials, voted during the process to ask OSHA to develop a standard. The Clinton administration had initially stated its intention to adopt a standard but decided not to.
Howell said it is still possible that some organizations may revive the idea of establishing a standard. OSHA Administrator John L. Henshaw, in a written statement announcing the manual, called it an important first step in arming employers with viable preventative measures. A spokesman said the agency could not elaborate on that comment.