Members of the American Conference of Governmental Industrial Hygienists, Inc. (ACGIH) met with key industry representatives from ILMA, American Petroleum Institute (API), and Organization Resource Counselors (ORC) to discuss ACGIH’s approach to broadening the scope of input for Threshold Limit Value (TLV) development and changes to their process. ACGIH representatives included ACGIH Executive Director Anthony Rizzuto, Vice Chair Elect Patrick Breysse, TLV Committee Chair Lisa Brosseau, and ACGIH outside counsel Steven Fellman.
Brosseau explained to attending industry representatives the process of reviewing and communicating TLVs under amendment consideration. ACGIH emphasized that it was not a standards setting organization, and that its TLVs are meant strictly as advice to industrial hygienists. In light of this mission, ACGIH does not see the need to build consensus on its recommendations, and views the process of reviewing large amounts of material submitted in response to proposed TLVs a burden. ACGIH is primarily an organization of volunteers who are unable to handle large volumes of data due to time constraints.
ACGIH provided ILMA with some advice on how to influence the TLV process, first by starting with the list of Chemical Substances and Other Issues Under Study. These are agents that could be placed on the Notice of Intended Changes list, and as such represent the earliest point at which concerns can be raised. ACGIH did say, however, that every TLV is always open for reconsideration, based on new information. Providing published literature reviews and documentation, as well as short and brief comments to the TLV Committee are necessary elements to factor when submitting information on a particular TLV.
ACGIH’s TLV Committee informed industry representatives with regard to the comments submitted by API, ILMA and ORC on the Mineral Oil Mists TLV, they have voted to keep the TLV on the Notice of Intended Changes list for 2002. Although there is no clear indication that there will be a symposium at this time, ACGIH is willing to have an initial dialog to discuss the "new" data that have surfaced since the original documentation of the TLV was developed. There would then be an internal decision by the TLV Committee as to whether a symposium is warranted. API, ILMA, and ORC offered financial and other support to ACGIH should the decision be to go ahead. ORC will make additional comments to ACGIH concerning the direction the TLV Committee should take in addressing mineral oil mists versus metal removal fluids, once we learn of its intent.
