Public Citizen Testimony Before OSHA Regarding Vinyl Chloride
By A'Ishah Johnson, MPH, DrPH(c), Public Citizen's Congress Watch
My name is A’Ishah Johnson, the Workers’ Health and Safety Advocate with Public Citizen. Public Citizen is a nonprofit consumer advocacy organization with over one million members and supporters. My work covers a range of worker health and safety issues, including chemical hazards in the workplace, informed by my background in public health and ongoing doctoral studies. Public Citizen has no financial conflicts of interest related to vinyl chloride, respiratory protection, or the issues addressed in this rulemaking.
OSHA proposes to eliminate a long-standing respiratory protection training requirement for vinyl chloride workers on the grounds that it is redundant. Public Citizen strongly opposes this proposal because OSHA has failed to demonstrate that the requirement is redundant or that removing the training will leave workers equally protected. In February 2023, five tank cars of vinyl chloride derailed in East Palestine, Ohio. Three days later, responders vented and burned the chemical rather than allowing it to cool. The National Transportation Safety Board later concluded that action was not necessary to prevent an explosion.[i] That incident is not the subject of today’s proposal, but it raises the same fundamental question about the same chemical: What happens when the people responsible for managing vinyl chloride lack complete, substance-specific knowledge of its hazards and controls? When the consequences of misunderstanding a hazard can be catastrophic, the answer should not be less training. Yet that is precisely what OSHA proposes.
Paragraph (j)(1)(iii) requires training on the purpose, proper use, and limitations of respiratory protection for every employee engaged in vinyl chloride or polyvinyl chloride operations. OSHA proposes to eliminate that requirement on the grounds that it duplicates the respiratory protection standard.[ii]
The requirement is not duplicative. Section 1910.134(k) requires training only for employees who are required to wear a respirator.[iii] Paragraph (j)(1) trains every employee in the operation, regardless of what they wear. For workers outside section 1910.134(k), this proposal eliminates training. OSHA’s own Advisory Committee on Construction Safety and Health deadlocked on consolidating chemical-specific respirator training into the general standard, because members questioned whether generalized training requirements adequately convey the specific hazards associated with individual substances.[iv] If OSHA’s own advisors are sounding the alarm on these rollbacks, the agency has not demonstrated that they are safe or redundant.
The problem is most apparent during emergencies. Under the vinyl chloride standard’s emergency procedures, workers who are not equipped with respiratory protection must evacuate and remain outside the affected area until conditions are safe. Deciding whether to evacuate depends on understanding what a respirator does and does not protect against, precisely what this training teaches and precisely what OSHA proposes to stop requiring for anyone not already wearing one. Workers also cannot rely on their senses to recognize danger. Federal guidance places vinyl chloride’s odor threshold at approximately 3,000 parts per million, roughly 3,000 times the OSHA permissible exposure limit.[v] A worker may be dangerously overexposed long before any odor is detected. Training serves as a substitute for a warning sign the chemical does not provide.
OSHA adopted the vinyl chloride standard in 1974 after determining that workers faced a grave danger from exposure, a threshold even higher than the significant-risk standard OSHA is not attempting to establish here.[vi] Subsequent evidence has only reinforced that concern. A mortality study of polyvinyl chloride polymerization workers found liver cancer mortality nearly three times higher than expected and found angiosarcoma of the liver, the disease most strongly associated with vinyl chloride exposure, at more than thirty times the rate observed among unexposed workers in the highest exposure groups.[vii] The hazards associated with vinyl chloride are substantial; the savings OSHA expects from removing this requirement are not.
OSHA estimates annual savings from eliminating this requirement at just $18,292 for approximately 4,400 workers, or about $4 per worker annually. At the same time, OSHA explicitly asks whether any safety benefit can be anticipated from the proposal and identifies none.[viii] In other words, OSHA proposes to remove a worker-protection requirement adopted in response to well-documented cancer risks in exchange for $4 per worker per year, without identifying any corresponding health or safety benefit.
Public Citizen urges OSHA to withdraw this proposal. If the agency believes some overlap exists, there is a straightforward solution: specify that training provided under section 1910.134(k) satisfies paragraph (j)(1)(iii) for workers already covered by that standard, while preserving the requirement for all other employees. That approach avoids any loss of training while ensuring that all workers remain protected.
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References
[i] NTSB releases illustrated Digest of East Palestine Investigation report. (2024, September 30). Retrieved August 12, 2026, from https://www.ntsb.gov/news/press-releases/Pages/NR20240930.aspx
[ii] Vinyl chloride. (2025, July 1). Federal Register. https://www.federalregister.gov/documents/2025/07/01/2025-11644/vinyl-chloride
[iii] 1910.134 – Respiratory protection. | Occupational Safety and Health Administration. (n.d.). https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134
[iv] Robertson, D. L. (2026, May 21). OSHA advisory Committee raises concerns over agency’s respirator standard overhaul. Jenner & Block. https://environblog.jenner.com/2026/05/21/osha-advisory-committee-raises-concerns-over-agencys-respirator-standard-overhaul/
[v] Vinyl Chloride | Medical Management Guidelines | Toxic Substance Portal | ATSDR. (n.d.). https://wwwn.cdc.gov/TSP/MMG/MMGDetails.aspx?mmgid=278&toxid=51
[vi] The New York Times. (1974, October 2). Safety rules issued for vinyl chloride. The New York Times. https://www.nytimes.com/1974/10/02/archives/safety-rules-issued-for-vinyl-chloride.html
[vii] A. Mundt, K., D. Dell, L., Crawford, L., & E. Gallagher, A. (2017, May 10). Quantitative estimated exposure to vinyl chloride and risk of angiosarcoma of the liver and hepatocellular cancer in the US industry-wide vinyl chloride cohort: mortality update through 2013. National Library of Medicine. Retrieved August 12, 2026, from https://pmc.ncbi.nlm.nih.gov/articles/PMC5629943/
[viii] Vinyl chloride. (2025b, July 1). Federal Register. https://www.federalregister.gov/documents/2025/07/01/2025-11644/vinyl-chloride