OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 18, 1987

Mr. Dennis J. Ruth
Rollins Environmental Services [NJ] Inc.
Post Office Box 221
Bridgeport New Jersey 08014

Dear Mr. Ruth:

This is in response to your letter of December 17, 1986, to Mr. John B. Miles, Jr., concerning the use of amyl nitrite pearls as an antidote for acrylonitrile poisoning.

As you noted in your letter, statements on using the pearls as an antidote are contained in Appendix A of the standard for acrylonitrile, 29 CFR 1910.1045. Appendices were included in the standard primarily for purposes of information. None of the statements contained therein should be construed as establishing a mandatory requirement not otherwise imposed by the main portion of the standard.

The amyl nitrile pearls are intended for use by persons properly trained in first aid in the period before medical aid can be obtained. If a qualified physician knows of an equal or better first aid substitute, the substitute may be used without any conflict with our regulations.

We appreciate the opportunity to clarify this matter for you. If we can assist you again in the future, we shall be glad to do so.

Sincerely,



Leo Carey, Director
Directorate of Field Operations




December 17, 1986

Mr. John B. Miles
Director of Field Operations
U.S. Department of Labor
Occupational Safety and Health
Administration
Washington, D.C. 20210

RE: 29 CFR 1910.1045-Appendix A III. F. Special First Aid Procedures: Acrylonitrile (AN)

Dear Mr. Miles:

Rolling Environmental Services (NJ) Inc., Logan Township, Bridgeport, New Jersey, requests clarification on the above referenced Standard. According to the information provided and required by the AN Standard, first aid kits containing an adequate supply (at least two dozen) of amyl nitrate pearls, each containing 0.3 ml, should be maintained at each site where acrylonitrile is used.... The problem that the company is experiencing is basically two-fold.

(1) a written prescription by a physician is required in order to obtain the pearls;

(2) the local physicians and pharmacies do not supply this medication inasmuch as they have stated it to be "as many as 25 years old".

The position, as stated by the company physicians, is that from the standpoint of modern medicine there are presently far better and more effective medications commercially available than amyl nitrate pearls which they would prefer us to use. Furthermore, it is unclear on initial checking by them exactly where this medication can be procured. In this regard, I would appreciate any guidance/recommendations on this matter that you can provide.

Thank you.

Very truly yours,



Dennis J. Ruth
Health and Safety Manager