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    Re: Pesticides in Workplace and exposure

    Posted by Caoimhín P. Connell on 2/15/04

    Hello Dr. PRS-

    The regulatory water can sometimes get a little murky when
    pesticides are involved.

    To begin with, regarding OSHA, states are either Fed-OSHA
    states or Home rule states. If my memory serves, Texas is a
    Fed OSHA state (and even if it isn’t it is also my memory
    that their pertinent regs are mirrors of the Fed OSHA). In
    any event, if it is a courthouse, then the employees will be
    employees of a “political subdivision” as defined by the OSH
    Act and therefore, OSHA would have absolutely no
    statutory jurisdiction anyway.

    I am familiar with only a few EPA regs and don’t pretend that
    pesticides is one of them… so…

    The fed pertinent OSHA regulations (which probably don’t
    apply in this case anyway) do not require prior notification
    and indeed do not require ANY notification. The regs do
    require that exposures be maintained to concentrations below
    specified concentrations. However, virtually none of the
    regulated materials are regulated with C&G Type reactions.
    Given the information you provided, I presume the pesticide
    was a probably a pyrethrin or pyrethroid (although some of
    the synthetics may also be haptans). If so, then the
    occupational exposure limit will be moot point any way since
    there is no PEL or AL for the pyrethoids or pyrethrin (and
    there is only a nuisance dust equivalent limit for
    pyrethrum). The concentrations of exposure needed to elicit
    an anaphylactic response would very likely be way below even
    the manufacturer’s recommended exposure limits (especially if
    antibody heavy chain attachment is involved).

    Feel free to pursue the matter a little further.

    Caoimhín P. Connell

    (The opinions expressed here are exclusively my
    personal opinions and do not necessarily reflect my
    professional opinion, opinion of my employer, peers, or
    professional affiliates. The above post is for information
    only and does not reflect professional advice and is not
    intended to supercede the professional advice of others.)


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