June 12, 1985

Mr. Keith W. Johnson
International President
International Woodworkers of America
1622 N. Lombard Street
Portland, Oregon 97217

Dear Mr. Johnson:

This is in response to your letter of May 8, on behalf of the International Woodworkers of America, in support of a petition submitted by the United Brotherhood of Carpenters and Joiners of America requesting that the Occupational Safety and Health Administration (OSHA) establish a new permissible exposure limit of 1 mg/m3 for all wood dusts. OSHA's scientific staff will evaluate the relationship between occupational exposure to wood dusts and cancer and other diseases as raised in your letter. Based on this review, the Agency will determine whether wood dusts present significant occupational hazards under existing working conditions. As part of this review, OSHA will also evaluate the applicability of the nuisance dust standard for application to wood dusts.

The comments of your organization will be considered in making this review. Your interest in occupational safety and health is appreciated.

Sincerely,



R. Leonard Vance, Ph.D.
Director Health Standards Programs




May 8, 1985

Mr. Robert Rowland, Asst. Secretary of Labor
Occupational Safety and Health Administration
200 Constitution Avenue, N. W.
Washington, D. C. 20210

Dear Mr. Rowland:

The International Woodworkers of America, AFL-CIO, CLC would like to go on record joining the United Brotherhood of Carpenters and Joiners, AFL-CIO, in their petition for a standard on wood dust, as reference in their letter of March 27, 1985. Please keep us advised of any rule-making activity, meetings or conferences pertaining to this matter.

We would reemphasize the literature cited by the Carpenters, and ask that you further consider the following documents in your deliberations:

(1) NIOSH Health Hazard Evaluation for Weyco-Longview
(2) NIOSH Draft Criteria Document on Wood Dust
(3) International Standards on Wood Dust
(4) Paper presented by John Lund to IBFWW in Geneva

The literature demonstrates that both standard setting organizations outside and within the United States, such as ACGIH and NIOSH, have recommended TLV's substantially lower than the 15 mg/m3 currently in effect for nuisance dust. As you can see from the Weyco-Longview HHE, an even lower TLV has been recommended for Western Red Cedar dust, to which many of our members in the Pacific Northwest are exposed.

It must be recognized that workers' compensation claims data will under-represent the frequency of adverse health effects flowing from workplace exposure to wood dust. Many would-be claims are not filed due to ignorance or confusion about applicable laws and regulations. There is also a reluctance of physicians to establish a probable connection between workplace exposure and the onset of symptoms. Further, the vast majority of claims filed for occupational illness on wood dust exposure, as the attached data from the Oregon Workers' Compensation Department shows, are denied. They are denied for a variety of reasons, including but not limited to, statute of limitation problems, lack of clear-cut evidence of causality and the influence, real or perceived, of other occupational and non-occupational factors (see for example the Labor Department's 1981 report of compensation of occupational diseases). These assertions are well-supported by the data we have seen, including the attached from Oregon.

Wood dust has been clearly documented in numerous field and epidemiological investigations as constituting a significant health risk, and such health risk warrants an adjustment in the workplace air contaminant standards. Wood dust is currently treated in the standards as a "nuisance" dust. As you may know, this designation is currently under review by the Occupational Safety and Health Review Commission in the Bemis case (Bemis Manufacturing v. OSHA, OSHRC Docket #80-3443).

Our contention is that wood dust is more than a "nuisance." It is a significant health risk that warrants a revision in the OSHA standards. Employers subject to the OSH Act need greater incentive to endeavor to reduce worker exposure. Existing sawmill and ventilation standards represent national consensus standards that have had little update since their adoption by reference into OSHA regulations. On their surface, it is our contention that they are more concerned with the fire and explosion hazards of wood dust rather than the health hazard. While we in no way wish to diminish the inherent fire hazard associated with wood dust, a lower TLV would mandate improved ventilation and work practices which would not only reduce the health risk, but enhance the fire prevention aspect as well.

Moreover, since most wood products mills recycle sawdust and chips for hog fuel or energy co-generation, the increased capture of wood dust due to the lower TLV might prove to be cost-effective. Improved work practices and ventilation systems might also reduce the amount of time clean-up workers spend "blowing down" accumulated dust with compressed air.

We firmly believe that a lower TLV is in the best interest of all concerned, and can be achieved with minimal additional cost.

We hope that you will begin rule-making procedures shortly, and request that we be made a full party to these proceedings.

If you should have any questions or require additional information, please don't hesitate to contact me. Thank you for your consideration in this matter.

Sincerely,



Keith W. Johnson
International President
International Woodworkers of America
1622 N. Lobard Street
Portland, Oregon 97217