ResH&S 2012 FINAL

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THE FLAVOR AND EXTRACT MANUFACTURERS ASSOCIATIONSafety and Health Act (Section 5(a)(1) of theAct) for broad authority over flavor manufacturingin general, and specifically for possibleexposure to diacetyl. OSHA also implementeda National Emphasis Program for microwavepopcorn manufacturing plants.Flavor manufacturers should be familiarwith, and comply with, the OSHA respiratorstandard. This standard remains the most commonsource of OSHA citations among flavormanufacturers.The federal Hazard CommunicationStandard applies to many areas of flavor manufacturing.OSHA issued specific guidance in2007 on hazard communication as it relates todiacetyl. OSHA has informally stated that thisguidance also applies to 2,3-pentanedione, althoughOSHA has not yet amended the 2007guidance to include this flavoring substance.OSHA’s confined space regulations mayapply to some flavor manufacturers employinglarge vessels or tanks in their operations.OSHA and NIOSH maintain web pageson flavorings-related lung disease. The OSHApage can be found at www.osha.gov/SLTC/flavoringlung/index.html.The NIOSH page canbe found at www.cdc.gov/niosh/topics/flavorings/current-niosh.html.NIOSH also maintainsa science blog on diacetyl and food flavorings atwww.cdc.gov/niosh/blog/nsb111008_diacetyl.html.Important information is availablethrough the NIOSH program of Health HazardEvaluations (HHEs). These are evaluationsconducted by NIOSH staff on a wide variety ofworkplaces. Several types of facilities relevantto the flavor industry have been evaluated byNIOSH, including microwave popcorn manufacturingplants and flavor manufacturing facilities.Reports of NIOSH HHEs are availableon the NIOSH website at www.cdc.gov/niosh/hhe/.CaliforniaIn 2006, the California Division of OccupationalSafety and Health (Cal/OSHA) implementedthe innovative program the FlavorIndustry Safety and Health Evaluation Program(FISHEP) with the assistance of FEMA. Thisprogram resulted in workplace safety consultationsby Cal/OSHA with flavor manufacturersoperating in California. FISHEP also resultedin the completion of serial spirometry testing ofseveral hundred California flavor manufacturingworkers. FISHEP assisted California flavormanufacturers in maintaining safe workplacesand also provided important information used inthe development and adoption of the Californiaflavor manufacturing workplace regulations.In 2010, California implemented aworkplace safety regulation specifically for flavormanufacturing in California. The regulationcontains a “1% cut-off” for diacetyl in compoundedflavors and contains provisions relatedto flavoring substances considered as “alternatives”to diacetyl – acetoin, 2,3-pentanedione,diacetyl trimer, 2,3-hexanedione, and 2,3-heptanedione.The state’s final statement of reasonsexplains the rationale for the regulations.WashingtonIn 2008, the Washington State Departmentof Labor and Industries published an informationsheet for restaurant owners and workersabout diacetyl. The sheet states that it “providesinformation to cooks and restaurant workersabout possibly harmful exposures to diacetylduring cooking.”3
RESPIRATORY HEALTH AND SAFETY IN THE FLAVOR MANUFACTURING WORKPLACEOccupational ExposureGuidelinesPermissible Exposure Limits and OccupationalExposure GuidelinesFew flavoring substances have permissibleexposure limits (PELs) promulgated byOSHA. PELs have the force of regulation andare an important way that OSHA regulates workplacesafety. Table 1 lists priority flavoring substanceswith OSHA PELs. Diacetyl and relatedsubstances such as 2,3-pentanedione and acetoinhave not been assigned PELs by OSHA.Three groups have published voluntaryoccupational exposure guidelines for diacetyl,and in one case for 2,3-pentanedione. Whilethey don’t have the regulatory authority of anOSHA PEL, these guidelines can be helpful toflavor manufacturers.The American Conference of GovernmentIndustrial Hygienists (ACGIH) publishesthreshold limit values (TLVs) and short-termexposure limits (STELs) for a wide variety ofcommercial substances including a small numberof flavoring substances. In 2010, ACGIHproposed a TLV and STEL for diacetyl that wereadopted in January, <strong>2012</strong>. The ACGIH TLV fordiacetyl is 0.01 ppm/8 hr. time-weighted average(TWA) and the STEL is 0.02 ppm/15 minutes.In 2010, the non-governmental nonprofitorganization Toxicology Excellence forRisk Assessment (TERA) proposed an occupationalexposure limit for diacetyl of 0.2 ppm/8hr. TWA (Maier et al., 2010).In its draft criteria document issued in2011, NIOSH recommended exposure limitsfor diacetyl and 2,3-pentanedione of 5 ppb/8hr. TWA and 9.3 ppb/8 hr. TWA, respectively.NIOSH also recommended short-tem exposurelimits for each substance in the draft criteriadocument – 25 ppb/15 minutes for diacetyl and31 ppb/15 minutes for 2,3-pentanedione.The three groups publishing occupationalexposure guidelines (TERA, ACGIH, andNIOSH) all employed different methods anddata in arriving at their conclusions. Brosseau(<strong>2012</strong>) commented on the need for the applicationof consistent best practices in the developmentof occupational exposure guidelines.Management andEmployee AwarenessThrough Education,Training and HazardCommunicationA variety of information resources areavailable for management from both OSHA andNIOSH on their websites on flavorings-relatedlung disease. The OSHA page can be found atwww.osha.gov/SLTC/flavoringlung/index.html.The NIOSH page can be found at www.cdc.gov/niosh/topics/flavoring. Among the available resourcesare an OSHA worker alert published in2010 and a NIOSH brochure for healthcare providerspublished in 2011.Thorough education and communicationamong both management and employees offlavor manufacturers are critical to the successof any workplace health and safety program.Formal, mandatory hazard communication and4
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ResH&S 2012 FINAL

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