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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