Should OSHA’s Standard for Ethylene Oxide be Revised?

We touched on this topic a couple of weeks ago when discussing generally if OSHA should consider updating its regulations of chemical sterilants. We came to the conclusion that it should, as there has been a large amount of new data on many chemicals commonly used in sterilization and disinfection, but that enforcement would be a key issue as well. This week, we’ll take a closer look at OSHA’s standard for Ethylene Oxide (1910.1047), which exists to protect those who may potentially be exposed to the sterilant gas. Specifically, we will focus on section d of that standard – “Exposure Monitoring”.

While the ultimate goal of the standard is to promote worker safety, section d serves to create a false sense of security for those using EtO at their facility. This section requires employers to take initial measurements and then, if the standards are met at that time, states that it is not necessary to measure again for as long as 6 months in some cases. Going against all logic, this section seems to claim that if there is not a problem now, there will not be one in the future. As we all know too well, equipment can fail, and accidents can and do occur.

What is the solution to this problem? Enforcing a simple Permissible Exposure Limit (PEL) would require employers to ensure that there is a safe work environment. Continuous monitoring of the workplace would ensure that employees are safe at ALL times, instead of just the times samples are taken as currently required in the standard. The bottom line is that accidents are always somewhat unexpected events. Telling employers that they “may rely on such earlier monitoring results to satisfy the requirements” greatly increases the likelihood that accidental leaks will not be detected.

When 1910.1047 was drafted in the early 1980s, continuous monitors were not readily available, which is certainly not the case today. Revising the EtO standard to match current technology is something that must happen if the goal of the document is to promote worker safety above all else.

1910.1047 can be found here:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10070