An Analysis of OSHA Compliance Inspections, 1990-2000
This article appeared in the October 15, 2002 issue of American Journal of Industrial Medicine. The abstract appears below.
Hexavalent chromium is widely recognized to be a lung carcinogen. However, the U.S. Occupational Safety and Health Administration (OSHA) has failed to reduce the permissible exposure limit (PEL), despite having acknowledged in 1994 that the current limit is too high. In 1993, Public Citizen and the Paper, Allied-Industrial, Chemical and Energy Workers International Union (PACE) petitioned to lower the PEL from the current 100 u g/m3 to 0.5 u g/m3 as an 8-hr time-weighted average (TWA).
To assess industry compliance with the current PEL, and to determine the feasibility of achieving the proposed lower limit of 0.5 u g/m3, we conducted a secondary data analysis of OSHA’s Integrated Management Information System (IMIS) database. This database contains 813 measurements of hexavalent chromium exposure from inspections performed during the years 1990-2000.
There was a statistically significant decline in the annual number of measurements over the study period from 127 in 1990 to 67 in 2000 (F = 0.0009; linear regression). The median TWA measurement was 10 u g/m3 (range: 0.01-13,960 u g/m3) and the median ceiling measurement was 40.5 m g/m3 (range: 0.25-25,000 u g/m3). Neither median TWA nor median ceiling exposures (if hexavalent chromium was detected) declined significantly during the study period (F = 0.065 and 0.57, respectively). Overall, 13.7% of TWA measurements were at or below the Public Citizen/PACE proposed standard; 65.0% were between the Public Citizen/PACE proposal and the current OSHA PEL; and 21.3% exceeded the OSHA PEL. Compared to OSHA measurements, state measurements were less likely to detect hexavalent chromium (40.2% vs. 52.1%; P = 0.0007; chi-square) and less likely to issue any citation (9.3% vs. 19.1%; P = 0.0003), including citations for overexposure if the exposure exceeded the PEL (54.8% vs. 78.8%; P = 0.012).
U.S. workers continue to be exposed to dangerously high hexavalent chromium levels, but low exposure levels were found in some industries. Further investigations should examine whether state plans provide weaker enforcement than federal OSHA. Am. J. Ind. Med. 42:378-383, 2002. © 2002 Wiley-Liss, Inc.