ResH&S 2012 FINAL

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, 2012. 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(2012) 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