1. Office of Worker Safety and Health Policy, AU-11:
Recent Safety and Health Regulatory and Policy Response Line Clarifications
October 4, 2016
HQ Facilitator
Office of Worker Safety and Health Policy, AU-11:
David Weitzman

2. Up-to-Date Standards ACGIH® TLVs® D16-05-001 ANSI® Lasers D16-05-002
Provide an Appropriate Level of Worker Protection
Acceptable to Implement for Compliance With 10 CFR 851
Standards Groups Occasionally Relaxed Earlier Controls That Had No Benefit

3. ACGIH® TLV EXCURSION LIMITS
10 CFR 851 Requires ACGIH® TLVs® When Lower Than 29 CFR 1910 PELs
TLVs® Include Using Excursion Limits for Substances with No STEL
851 Therefore Includes Using Excursion Limits
Should review the documentation of the TLVs® D

4. Unbound Engineered Nanoparticles (UNP) in Common Materials
Engineered Nanoscale Particles
Commonly Available Nano-enabled Products May Have Adverse Health Effects
DOE Order 456.1
Applies to All UNP
Products That Contain UNP Must Implement O 456.1 D

5. Temporarily Energizing LoTo’d Equipment
10 CFR 851 Incorporates 29 CFR
Allows Temporary Energizing for Testing or Positioning
Sequence of 5 Actions Must Be Followed
At Permanent Location or Maintenance Shop D

6. Exposure Compliance with Respiratory Protection
10 CFR 851 Incorporates 29 CFR (b)
If Hierarchy Controls are Implemented:
Documented Exposure Remains Outside Respirator
Outside Exceedances are Technical Exceedances
Exception: OSHA Cd is Not Exceedance
Documentation May Include Calculated Assigned Protection Factor D

7. Respiratory Protection Requirements for Unexpected IDLH Exposure
10 CFR 851 Incorporates (d)(3)
Provide respiratory protection for reasonably foreseeable emergency
Respiratory Protection for IDLH:
If Work Planning Identifies Potential IDLH
Not Required if Not Reasonably Foreseen D

8. Response Line Web: Contact:
Contact:
Carol Sikora: