OSHA Instruction STD 1-4.2 October 30, 1978

MEMORANDUM FOR: REGIONAL ADMINISTRATORS

FROM: DONALD E. MACKENZIE DIRECTOR, FIELD COORDINATION

SUBJECT: Classification of Polychlorinated Biphenyls (PCBs) Standards

OSHA does have specific standard for airborne levels for two isomers of PCBs and they are listed in 29 CFR 1910.1000 table Z-1. These forms are chlorodiphenyl (42% and 54% chlorine). These above compounds are the more common compounds found as insulating liquids used in electrical capacitors, transformers, and nuclear reactors. Other chemical forms of PCBs exist, such as chlorodiphenyl (16%, 21%, 71% chlorine), and are used in heat transfer enclosures and in investment casting waxes in foundries.

Repeated skin contact hazards with all PCB's could be addressed by the standards 1910.132 and 1910.133.

The "General Duty Clause" section 5(a)(1) of the OSH Act would apply when serious hazards could be documented on a case by case basis and specific health standards do not apply. This may include the following:

A. Poor personal hygiene practices B. Inadequate employee training programs C. Compounds other than those covered by specific standards

OFC:SMallinger:bf:6/28/78