Recommendations for Consideration by the U.S. Secretary of Labor on the
Adoption and Use of Occupational Exposure Limits by Federal Agencies

Prepared by the

Federal Advisory Council on Occupational Safety and Health

(FACOSH)



Executive Summary

Because the Occupational Safety and Health Administration’s (OSHA’s)
Permissible Exposure Limits (PELs) have remained unchanged since their
adoption on May 29, 1971, and do not account for 40 years of advances in
technology or the latest peer-reviewed published toxicological
information, the Federal Advisory Council on Occupational Safety and
Health (FACOSH) asked its Emerging Issues Subcommittee to analyze
Federal agencies’ use of PELs.  The Subcommittee examined how Federal
Executive Branch agencies use occupational exposure limits (OELs)
published by other agencies, professional organizations, and other
foreign or domestic entities.

The Subcommittee considered all aspects of controlling a potential
hazardous chemical in the workplace including risk assessment approaches
and the hierarchy of controls.  The Subcommittee concluded that FACOSH
should recommend that Executive Branch departments and agencies use the
most protective, and technologically and economically feasible OELs in
Federal workplaces, notwithstanding the existence of a PEL for a given
substance of concern; require contractors, subcontractors, recipients,
and subrecipients to use the most protective, technologically and
economically feasible OEL while working on behalf of the Federal
government; and designate a person deemed to be competent by virtue of
training and experience to make recommendations regarding acceptable
chemical exposure risks, appropriate OELs, and employee exposure
controls.   

Introduction

Although the current PELs have existed unchanged since their adoption on
May 29, 1971, scientific research is continually re-evaluating
occupational exposure limits and their effectiveness in protecting
workers.  The Federal Advisory Council on Occupational Safety and Health
(FACOSH) asked its Emerging Issues Subcommittee to evaluate the existing
OSHA PELs, based on American Conference of Governmental Industrial
Hygienists (ACGIH®) Threshold Limit Values (TLVs®) developed in 1968,
and determine which, if any, should have their levels adjusted to be
more protective of Federal workers.  In addition, the Council asked the
Subcommittee to propose mechanisms for implementing these PEL
recommendations in federal agencies.  

The Subcommittee examined the current situation with respect to how
Federal Executive Branch agencies use OELs for risk management and
control.  Given that OSHA sets minimum standards for workplace safety
and health and that the Federal government strives to exceed the minimum
as a model employer, the Subcommittee determined that current PELs are
not always adequate to protect Federal employees, or employees of
contractors providing services to the Federal government.

In this paper, an OEL refers generically to one or more accepted
exposure limits including the OSHA-regulated PELs, NIOSH Recommended
Exposure Limits (RELs), ACGIH® TLVs®, the American Industrial Hygiene
Association (AIHA®) Workplace Environmental Exposure Levels (WEELs™),
or any occupational exposure limits set by other agencies,
organizations, and foreign or domestic entities, such as Germany’s
Maximale Arbeitsplatz-Konzentration (MAK) limits.  The Subcommittee
reviewed a number of significant background documents, including
Executive Order (EO) 12196 and other legal authorities, which provided
information on workplace safety and health, occupational exposure
limits, risk management, hazard assessment, and the requirements for
protecting Federal civilian and contract employees.

Background

The Occupational Safety and Health Act of 1970 (the Act) created OSHA
and provided the authority for the Agency to set standards regulating
occupational safety and health.  Section (6)(a) of the Act allowed the
Secretary of Labor to, “…by rule promulgate as an occupational
safety and health standard any national consensus standard and any
established Federal  standard….”  Under this two-year authority, 
OSHA adopted the current PELs, which were based on the ACGIH® TLVs® in
effect in 1968.  Since 1972 any changes or additions to PELs require
following the formal rulemaking process, which has hindered attempts to
add new PELs or update others.  

Over time, advances in scientific knowledge have led to a greater
understanding of adverse effects, and NIOSH and professional
organizations like the ACGIH® and AIHA® have responded by issuing new
or modifying existing OELs.  When modified, more OEL values have
decreased than have increased.  For example, a comparison of the TLVs®
from 1968 to 2011 reveals that over 200 TLVs® have decreased while only
a half dozen have increased.  A table comparing OSHA’s PELs to other
OELs is included as Appendix IV.  

It is unlikely that OSHA will promulgate significant numbers of new
PELs.  Federal agencies can address this lack of regulatory progress by
applying risk management principles and alternative OELs to occupational
exposures. 

Process and Standards

As a mechanism to protect Federal employees, Federal agencies should use
a risk assessment to determine whether a workplace exposure constitutes
a hazard and then evaluate existing OELs to select the appropriate OEL.

Risk Assessment

A risk assessment considers all aspects of the potential hazard and
risks in the workplace, including OELs, work procedures, and systems of
work.  If an agency’s risk assessment concludes that employees could
suffer negative effects from exposure to a given hazard, then the agency
should follow a risk management strategy based on the hierarchy of
controls to reduce or eliminate the hazard.  The hierarchy of controls
includes, in order of preference: 

Eliminate the need to use the substance; 

Substitute a less hazardous substance; 

Implement engineering controls (i.e. local exhaust ventilation,
barriers, etc.)

Implement work practice controls and training;

Implement administrative controls (i.e. work restrictions/job or task
rotation); and in addition to these control methods, and only as a last
resort:

Proper selection, fitting, and use of personal protective equipment.

Consideration of Existing OELs

Once a Federal agency has performed a risk assessment and proceeded
through the hierarchy of controls to conclude that a specific substance
cannot be eliminated from the workplace, then the agency must select an
appropriate workplace OEL.  The OEL selection process begins by
examining existing substance-specific OELs.  If an OSHA PEL exists, OSHA
regulations require that employee exposures do not exceed that PEL.  If
OSHA does not have a PEL, then the examination must expand to other
exposure limits such as, but not limited to, RELs or TLVs®.  Of course,
even if a PEL exists, other OELs may be more protective.  

When examining OELs, the agency should be aware of the background of a
given limit and the methods the defining organization used to select
that limit.  For protection from radioactive materials, the
non-quantitative exposure limit is “ALARA” or As Low as Reasonably
Achievable.  For some situations, an ALARA approach would require either
substituting a less-hazardous chemical into the existing process or
changing the process entirely to eliminate the need for the chemical.  

Previously, many NIOSH RELs for carcinogens were set based on the
similar non-quantitative concept of Lowest Feasible Concentration (LFC).
 Some RELs were assigned values at the limits of detection for the
analytical method in use at the time.  

Currently, NIOSH bases its RELs on risk evaluations using human or
animal health effects data, and on an assessment of what levels can be
feasibly achieved by engineering controls and measured by analytical
techniques.  For all workplace hazards, including carcinogens, NIOSH
tries to specify not only a no-effect exposure, but also exposure levels
at which there may be residual risks.  

When selecting an appropriate OEL, the agency must consider the
potential for mixed exposures, also referred to as cumulative risk. 
OSHA’s Air Contaminants standard, 29 CFR 1910.1000, describes
computation formulae for determining cumulative and mixed exposures. 
Cumulative exposure refers to different levels of exposure to the same
substance while mixed exposure refers to combined exposures to more than
one substance.  An expert system known as “Mixie” is a useful tool
that can assist in applying the mixture formula for exposure
combinations. 

Another method for refining exposure strategies applies the generic
principles of a control banding or hazard banding approach.  This
approach categorizes (“bands”) chemicals according to their
toxicological characteristics.  Hazard banding, developed by the United
Kingdom’s Health and Safety Executive (HSE) as part of a program known
as Control of Substances Hazardous to Health (COSHH) Essentials and
pioneered in the pharmaceutical industry, can be useful if no OEL
exists.  The HSE developed an expert system as part of COSHH Essentials
to guide the user through a series of questions leading to an
appropriate control strategy.

Current Policies

Some Federal agencies already apply their own standards for OEL
selection:

Department of State

Permissible exposure limits (PELs) for occupational exposure to toxic
and hazardous materials and hazardous physical energies are those
published by the Department of Labor under 29 CFR Part 1910.  An
exception is when the threshold limit value (TLV®), established by the
American Conference of Governmental Industrial Hygienists (ACGIH®), is
lower than the OSHA PEL.  In this case, the TLV® becomes the exposure
standard for the Department of State.  If neither a PEL nor a TLV®
exists, the National Institute for Occupational Safety and Health
(NIOSH) recommended exposure limit (REL) becomes the Departmental
exposure standard.

15 FAM 952  EXPOSURE STANDARDS

(CT:OBO-4;   12-21-2005)

(Uniform State/USAID/Commerce/Agriculture)

Department of Energy

§ 851.23 Safety and health standards.

(a)	Contractors must comply with the following safety and health
standards that are applicable to the hazards at their covered workplace:

(1)	Title 10 Code of Federal Regulations (CFR) 850, ‘‘Chronic
Beryllium Disease Prevention Program.’’

(2)	Title 29 CFR, Parts 1904.4 through 1904.11, 1904.29 through 1904.33;
1904.44, and 1904.46, ‘‘Recording and Reporting Occupational
Injuries and Illnesses.’’

(3)	Title 29 CFR, Part 1910, ‘‘Occupational Safety and Health
Standards,’’ excluding 29 CFR 1910.1096, ‘‘Ionizing
Radiation.’’

(4)	Title 29 CFR, Part 1915, ‘‘Shipyard Employment.’’ 

(5)	Title 29 CFR, Part 1917, ‘‘Marine Terminals.’’

(6)	Title 29 CFR, Part 1918, ‘‘Safety and Health Regulations for
Longshoring.’’

(7)	Title 29 CFR, Part 1926, ‘‘Safety and Health Regulations for
Construction.’’

(8)	Title 29 CFR, Part 1928, ‘‘Occupational Safety and Health
Standards for Agriculture.’’

(9)	American Conference of Governmental Industrial Hygienists (ACGIH®),
‘‘Threshold Limit Values for Chemical Substances and Physical Agents
and Biological Exposure Indices,’’ (2005) (incorporated by
reference, see § 851.27) when the ACGIH® Threshold Limit Values
(TLVs®) are lower (more protective) than permissible exposure limits in
29 CFR 1910. When the ACGIH® TLVs® are used as exposure limits,
contractors must nonetheless comply with the other provisions of any
applicable expanded health standard found in 29 CFR 1910.

(10)	American National Standards Institute (ANSI) Z88.2, ‘‘American
National Standard for Respiratory Protection,’’ (1992) (incorporated
by reference, see § 851.27).

(11)	ANSI Z136.1, ‘‘Safe Use of Lasers,’’ (2000) (incorporated
by reference, see § 851.27).

(12)	ANSI Z49.1, ‘‘Safety in Welding, Cutting and Allied
Processes,’’ sections 4.3 and E4.3 (1999) (incorporated by
reference, see § 851.27).

(13)	National Fire Protection Association (NFPA) 70, ‘‘National
Electrical Code,’’ (2005) (incorporated by reference, see §
851.27).

(14)	NFPA 70E, ‘‘Standard for Electrical Safety in the
Workplace,’’ (2004) (incorporated by reference, see § 851.27).

(b)	Nothing in this part must be construed as relieving a contractor
from complying with any additional specific safety and health
requirement that it determines to be necessary to protect the safety and
health of workers. 

Department of Defense (by Service):

DoD:  DoD requires compliance with the OSHA PELs as a part of policy
requiring compliance with OSHA standards.  The DoD Components (Military
Services and Defense Agencies) are authorized to issue more stringent
requirements to meet their needs.  DoD policy provides procedures for
developing Alternate or Supplemental Standards under 29 CFR 1960.

Army:  Army policy requires use of the most stringent of either OSHA
PELs or ACGIH® TLVs® (Department of the Army Pamphlet 40-503,
Industrial Hygiene Program,  HYPERLINK
"http://www.apd.army.mil/pdffiles/p40_503.pdf"
http://www.apd.army.mil/pdffiles/p40_503.pdf ).

Navy/Marine Corps:  Uses standards in the following order of precedence:

1989 OSHA permissible exposure limits (PELs) ( HYPERLINK
"http://www-nehc.med.navy.mil/ih/ihfom.htm"
http://www-nehc.med.navy.mil/ih/ihfom.htm )

2.	Substance-specific OSHA standards

3.	Navy-developed standards

4.	American Conference of Governmental Industrial Hygienists (ACGIH®)
threshold limit values (TLVs®)

Air Force:  For occupational health assessments, the industrial hygiene
office (“Bioenvironmental Engineering”) determines the appropriate
Occupational and Environmental Exposure Limit (OEEL) using Air Force
standards or the most appropriate exposure limit adopted from
established, recognized standards (AIR FORCE MANUAL 48-155, Occupational
and Environmental Health Exposure Controls,  HYPERLINK
"http://www.e-publishing.af.mil/shared/media/epubs/AFMAN48-155.pdf"
http://www.e-publishing.af.mil/shared/media/epubs/AFMAN48-155.pdf )

ACGIH® TLVs®

2.	OSHA PELs

3.	Emergency Response Planning Guidelines (ERPGs)

4.	AIHA Workplace Environmental Exposure Levels (WEELs™)

5.	Technical Guide 230 (TG-230), Chemical Exposure Guidelines for
Deployed Military Personnel

Limitations of Occupational Exposure Limits

An OEL can indicate the level of hazard posed by exposure to a specific
substance but, by itself, cannot determine the likelihood of adverse
health effects from that exposure.  With regard to using TLVs® and
biological exposure indices (BEIs®), ACGIH® notes that, “TLVs® and
BEIs® should NOT be adopted as standards without an analysis of other
factors necessary to make appropriate risk management decisions.  Any
use of a TLV® or BEI® in a regulatory context should include a careful
evaluation of the information in the written  HYPERLINK
"https://www.acgih.org/store/BrowseProducts.cfm?type=cat&id=16"
documentation  and consideration of all other factors as required by the
statutes which govern the regulatory process of the governmental body
involved.”  

OEL Selection

Federal agencies may use more protective exposure limits, beyond the
PELs.  However, they should use the full risk assessment process and be
aware of the guidelines, considerations, and limitations of various
exposure limits.  To assist agencies in determining an appropriate OEL
for a given situation, the Subcommittee recommends selecting a
“competent person” to use a risk assessment approach.  See Appendix
I for a sample decision logic.

Competent Person

Assessing chemical exposures in the workplace, evaluating exposure risk
to employees, and making recommendations on acceptable employee chemical
exposure levels based on the risk, requires a person who is competent to
perform these activities.  A person is deemed to be competent by way of
training and/or experience. 

A person possessing one of the following qualifications is considered
competent for assessing chemical exposure risks, and making
recommendations regarding acceptable chemical exposure risks,
appropriate OELs, and employee exposure controls:  

Certification by an accredited body such as the American Board of
Industrial Hygiene (ABIH) or the Board of Certified Safety Professionals
(BCSP).  A Certified Industrial Hygienist (CIH®) or Certified Safety
Professional (CSP®) has not only met minimum requirements for education
and experience but has also demonstrated a minimum level of knowledge
through examination.  These designations are uniquely dedicated to
occupational safety and health.

GS-0690-11 or above – by virtue of education, experience, and job
complexity defined as such:  Inspections cover the full range of
industries, including such large and diverse industries as the
automotive, plastic, and rubber industries.  These industries pose a
number of complex problems for the industrial hygienist, resulting from
the size and diversity of work operations, the use of exotic chemicals,
and the combinations of hazardous materials.  The employee must adapt or
modify past practices and research trends in the field in order to
identify and evaluate a wide variety of occupational health hazards. 
Fatality investigation is complicated by the requirement to investigate
conditions which existed prior to the accident and may have changed.

Bachelor’s degree in science or engineering (e.g. chemistry, biology,
toxicology, public health, chemical/environmental engineering) from an
accredited* institution and five years progressively more complex
experience covering full spectrum of occupational health hazards (job
experience complexity comparable to GS-0690-11). 

*Note:	An accredited college/university is one accredited by a regional
or national accrediting agency recognized by the U.S. Secretary of
Education.

Master’s degree in science or engineering from an accredited
institution and four years progressively more complex experience
covering the full spectrum of occupational health hazards (job
experience complexity comparable to GS-0690-11).

Other accredited certifications may also be indicators of competency in
this regard.  Some examples of such certifications include, but are not
limited to: Professional Engineer (PE), particularly in chemical,
environmental, or safety engineering; Certified Hazardous Materials
Manager (CHMM); Qualified Environmental Professional (QEP); or
certification by the American Board of Toxicology (ABT).

Legal Considerations

EO 12196, paragraph 1-201(d); The Act, Section 19(a); and 29 CFR 1960,
Subpart C, all require that federal workplaces and working conditions be
safe and healthful and free from recognized serious hazards.  They also
require agencies to comply with all applicable OSHA standards issued
under Section 6 of the Act – or an approved alternate standard.  29
CFR 1960.16, Compliance with OSHA Standards, authorizes agencies to,
“… upon prior notification to the Secretary, prescribe and enforce
more stringent permissible exposure levels or threshold limit values
….”  

According to 29 CFR 1960.18, if there is no OSHA standard that applies
to a particular worksite, job, condition, or other workplace exposure,
an agency must implement an emergency temporary supplemental standard to
protect its employees.  Subsequent to implementing an emergency
temporary supplemental standard, the agency must develop and implement a
permanent supplemental standard to continue to assure a safe and
healthful workplace and adequate employee protection.

Action

Given the requirements of the OSH Act, EO 12196, and 29 CFR Part 1960,
and that current PELs are inadequate to protect Federal employees and
Federal contractor employees, FACOSH recommends that:

The Secretary of Labor submit to the President a recommendation for an
updated Executive Order to amend EO 12196, Occupational Safety and
Health Programs for Federal Employees, directing the heads of Executive
Branch departments and agencies to require the use of the most
protective, and technologically and economically feasible OELs as
published by a recognized research or regulating body, in Federal
workplaces, notwithstanding the existence of a PEL for a given substance
of concern.  

The Secretary of Labor include in the recommendation to the President
that Federal Executive Branch departments and agencies, in procurement
contracts, grants, and cooperative agreements, to the extent authorized
by applicable statutory authority, require contractors, subcontractors,
recipients, and subrecipients to use the most protective,
technologically and economically feasible OEL while carrying out work on
behalf of the Federal government.  Contractors and grant applicants who
propose to use the most protective OELs may be given preference for
awards of contracts and grants, respectively.

A person deemed to be competent by virtue of training and experience
make recommendations regarding acceptable chemical exposure risks,
appropriate OELs, and employee exposure controls.  Recommendations on
OELs may be based on factors such as toxicity of the chemical, length
and frequency of exposure, analytical limit of detection, and
technological and economic feasibility. 

Sample language for an updated Executive Order is provided as Appendix
II. 

Other Issues

In addition to examining the use of OELs in the Federal government, the
FACOSH Emerging Issues Subcommittee identified other issues that may be
of interest to FACOSH.  They are as follows:

Occupational Exposure to Noise

NIOSH has a recommended exposure limit (REL) for occupational noise
exposure of 85 decibels, A-weighted, as an 8-hour time-weighted average
(85 dBA as an 8-hr TWA) compared to OSHA’s PEL of 90 dBA as an 8-hr
TWA.  Since the measurement of decibels is a logarithmic rather than
linear scale, the OSHA PEL is substantially less protective than the
NIOSH REL.

OSHA uses a 5-dB exchange rate instead of the 3-dB exchange rate that is
supported by scientific evidence for assessing hearing impairment as a
function of noise level and duration.  In the Federal sector, DoD, the
Environmental Protection Agency, and the National Aeronautic and Space
Administration use the 3-dB exchange rate, as do nearly all other
governments worldwide, including Canada, China, the United Kingdom, and
Germany. 

Dispersible Engineered Nanomaterials (DENMs)

OSHA defines nanomaterials as, “materials that have been purposefully
manufactured, synthesized, or manipulated to have a size with at least
one dimension in the range of approximately 1 to 100 nanometers and that
exhibit unique properties determined by their size.”

Published scientific studies have indicated that at least some DENMs are
biologically active, have produced toxicological reactions in the lungs
of exposed experimental animals, and may readily penetrate intact human
skin.  While DENMs are truly an emerging issue and published results are
not plentiful, scientists and Federal agencies, such as NIOSH, continue
to conduct research to fully understand the potential health effects of
exposure.  

Currently, both scientists and Federal agencies agree that DENM toxicity
depends heavily on the physical and chemical properties of the
nanoparticles, such as particle size and size distribution,
agglomeration state, shape, crystal structure, chemical composition,
surface area, surface chemistry, surface charge, and porosity, and that
these properties may differ substantially from those of the same
material in macro-scale form. 

Work-Related Musculoskeletal Disorders

According to OSHA, a musculoskeletal disorder (MSD) is a disorder, “of
the muscles, nerves, tendons, ligaments, joints, cartilage or spinal
discs that was not caused by a slip, trip, fall, motor vehicle accident
or similar accident such as carpal tunnel and back pain.”  OSHA notes
that MSDs are among the most commonly reported work-related injuries. 
Conservative estimates of the economic burden resulting from MSDs, as
measured by compensation costs, lost wages, and lost productivity, are
between $45 and $54 billion annually.  

Most Executive Branch agencies report some level of awareness of MSDs,
and DoD has issued a policy requiring the implementation of an
Ergonomics Program.  However, OSHA does not have a standard that
directly addresses the causes of MSDs or the improperly designed or
performed jobs or activities in Federal workplaces, such as airports,
warehouses, mailrooms, and other environments, that may contribute to
MSDs.

Ionizing Radiation

The use of ionizing radiation in the Federal workplace has grown
substantially in recent years.  For example, the use of X-ray equipment
and gamma-ray imaging devices to inspect luggage, packages, and other
items has become widespread.  Ionizing radiation is also used to
neutralize harmful biological agents, including anthrax, as well as
microorganisms in certain food.  

In 1971 OSHA adopted as its Ionizing Radiation standard the radioactive
materials exposure limits that the Atomic Energy Commission (which
preceded the Nuclear Regulatory Commission (NRC)) issued in 1969 (10 CFR
Part 20, including Appendix B, Tables I and II).  In general, the OSHA
rule, 29 CFR 1910.1096, applies when an individual in a workplace does
not fall under regulations provided by NRC or an equivalent Agreement
State.  Much like 10 CFR 20, 29 CFR 1910.1096 specifies dose limits and
training requirements for individuals who will work in restricted areas,
etc.  However, unlike 10 CFR 20, 29 CFR 1910.1096 is still based on
limits and models promulgated in 1969.

Working in Extreme Temperatures

	Heat

OSHA reports that every year thousands of workers become sick from heat
exposure on the job.  And that workers exposed to hot and humid
conditions are at risk of heat illness, especially those doing heavy
work tasks or using bulky protective clothing and equipment.  OSHA has
instituted the Campaign to Prevent Heat Illness in Outdoor Workers with
extensive guidance and other information on preventing heat-related
illness.  It has also compiled references to standards and technical
procedures for assessing and controlling heat stress.

Although there is no standard for heat stress, OSHA and DoD, and other
organizations such as ACGIH® and NIOSH, have provided information and
guidance.

Cold

With regard to exposure to cold temperatures, OSHA’s Fact Sheet,
Protecting Workers in Cold Environments, states that prolonged exposure
to freezing temperatures can result in health problems as serious as
trench foot, frostbite, and hypothermia.  And that wind chill, a
combination of temperature and velocity, is a crucial factor to evaluate
when working outside.  

References reviewed indicate no clear standard limiting the amount of
cold to which a person would be exposed.  Instead, guidelines are
provided for planning worker exposure to cold, including identifying
clothing to be worn while working in cold environments.

NIOSH has developed guidance for preventing hypothermia, frostbite,
trench foot, and chilblains along with web links to a variety of
references from other organizations.

The Army issued TB MED 508, Prevention and Management of Cold-Weather
Injuries, with broad guidance directed at the individual military
service member, supervisors, commanders, and health staff.  Guidance
includes recommended insulating value of clothing to be worn based on
air temperature and worker physical activity level.

Appendix I –OEL Decision Logic

(Carcinogen, Mutagen, Teratogen

†Dispersible Engineered Nanomaterial

‡The Lowest Feasible Level concept involves evaluating the strengths
and weaknesses of economic, technological, analytical, and environmental
data and determining what level can be achieved for most operations most
of the time, being cognizant of human health and business enterprise,
which involves some risk in expectation of benefit.

Appendix II – Sample Executive Order Language

Executive Order 13###--Occupational safety and health programs for
Federal employees – Revision to Executive Order 12196

Source: The provisions of Executive Order 12196 of Feb. 26, 1980, appear
at 45 FR 12769, 3 CFR, 1980 Comp., p. 145, unless otherwise noted.

By the authority vested in me as President by the Constitution and
statutes of the United States of America, including Section 7902(c) of
Title 5 of the United States Code and in accord with Section 19 of the
Occupational Safety and Health Act of 1970, as amended (29 U.S.C. 668),
it is ordered:

Section 1-201 in E.O. 12196 is hereby modified by inserting new
paragraph (e) to read:

1-201.  The head of each agency shall: 

(e) with respect to control of exposure to toxic materials, require the
use in Federal workplaces of the most protective, technologically and
economically feasible occupational exposure limit as published by a
recognized research or regulating body, notwithstanding the existence of
a permissible exposure limit for a given substance as may have been
promulgated under Section 6 of the Act.    

Section 1-201 in E.O. 12196 is further modified by reassigning
paragraphs letters as follows:

Paragraph (e) becomes (f); (f) becomes (g); (g) becomes (h); (h) becomes
(i); (i) becomes (j); (j) becomes (k); (k) becomes (l); (l) becomes (m).

Appendix III: Subcommittee Participants

The following list contains the names of FACOSH members, technical
experts, and OSHA staff who actively participated on the Emerging Issues
Subcommittee during its analysis of the current PELs.

FACOSH Members

Donald Bathurst, Chief Administrative Officer, U.S. Department of
Homeland Security

William “Chico” McGill, Director, Government Employees Department,
International Brotherhood of Electrical Workers

Milagro “Milly” Rodriguez, MPH, Occupational Health and Safety
Specialist, American Federation of Government Employees

Special Agency Liaison

Frank Hearl, PE, Chief of Staff, National Institute of Occupational
Safety and Health, Centers for Disease Control and Prevention, U.S.
Department of Health and Human Services

Technical Experts

John Seibert, CSP, Assistant for Safety, Health & Fire, Office of the
Deputy Under Secretary of Defense (Installations & Environment), U.S.
Department of Defense

Camille Carraway, CIH, Industrial Hygienist, U.S. Department of Homeland
Security

Jason Capriotti, CIH, CSP, Industrial Hygienist, National Institute of
Standards and Technology, U.S. Department of Commerce 

Daniel Marsick, PhD, CIH, CSP, Industrial Hygienist, U.S. Department of
Energy

Tony Pierpoint, PhD, CIH, Assistant Director, Safety and Health, U.S.
Department of Homeland Security

Joseph Beres, CIH, CSP, PE, Industrial Hygienist, U.S. Department of
State

Azita Mashayekhi, MHS, Staff Industrial Hygienist, International
Brotherhood of Teamsters

Dennis Phelps, International Representative, International Brotherhood
of Electrical Workers (IBEW)

Jeff Friday, National Counsel, National Treasury Employees Union

James R. Thornton, CIH, CSP, Director, Environmental Health and Safety,
Newport News Shipbuilding

OSHA Staff

Francis Yebesi, Director, Office of Federal Agency Programs,
Occupational Safety and Health Administration, U.S. Department of Labor

Lorree Probert, Program Analyst, Office of Federal Agency Programs,
Occupational Safety and Health Administration, U.S. Department of Labor

Loretta D. Schuman, PhD, MS, DABT, Senior Toxicologist, Office of
Chemical Hazards (Nonmetals), Occupational Safety and Health
Administration, U.S. Department of Labor

David Ward, CSP, Safety Specialist, Office of Federal Agency Programs,
Occupational Safety and Health Administration, U.S. Department of Labor

Appendix IV – Comparison of the OSHA PELs with Other OELs

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	HPV	 	 	 	5 C	 	 		

Terphenyl o-	84-15-1	 	 	 	 	5 C	 	 		

Terphenyl p-	92-94-4	HPV	 	 	 	5 C	 	 		

tert-Amyl methyl ether [TAME]	994-05-8	HPV	 	 	 	 	 	 		

tert-Pentane [Neopentane]	463-82-1	HPV	 	 	 	 	1000	2000 ST		

Tetrachloro-1,2-difluoroethane [FC-112] 1,1,2,2-	76-12-0	 	500	500	500
 	200	400 ST		

Tetrachloro-2,2-difluoroethane [FC-11 2a] 1,1,1,2-	76-11-9	 	500	500
500	 	200	400 ST		

Tetrachloroethane 1,1,2,2-	79-34-5	HPV	5	1	1	 	1	2 ST		

Tetrachloroethylene [Perchloroethylene]	127-18-4	HPV	100	25 and 300 C	 
 	 	 		

Tetrachloronaphthalene	1335-88-2	 	2	2	2	 	 	 		

Tetrachloropyridine 2,3,5,6-	2402-79-1	HPV	 	 	 	 	 	 		

Tetrachlorosilane	10026-04-7	 	 	 	 	 	 	 		

Tetraethyl lead (as Pb)	78-00-2	HPV	0.075	0.075	0.075	 	0.05	0.1 ST	


Tetraethylene glycol diacrylate	17831-71-9	 	 	 	 	 	 	 		

Tetrafluoroethane [HFC 134a] 1,1,1,2-	811-97-2	HPV	 	 	 	 	1000	8000
ST		

Tetrafluoroethylene	116-14-3	HPV	 	 	 	 	 	 		

Tetrahydrofuran	109-99-9	HPV	200	200	200	250 ST	50	100 ST		

Tetrahydrofurfuryl alcohol	97-99-4	HPV	 	 	 	 	 	 		

Tetramethyl lead (as Pb)	75-74-1	 	0.075	0.075	0.075	 	0.05	0.1 ST	


Tetramethyl succinonitrile	3333-52-6	 	0.5	0.5	0.5	 	 	 		

Tetranitromethane	509-14-8	 	1	0.005	1	 	 	 		

Tetrasodium pyrophosphate	7722-88-5	 	 	5	5	 	 	 		

Tetryl	479-45-8	 	1.5	1.5	1.5	 	 	 		

Thallium - Elemental	7440-28-0	 	 	0.1	 	 	 	 		

Thallium - Soluble compounds (as Tl)	7440-28-0	 	0.1	0.1	0.1	 	 	 
	

Thimerosal	54-64-8	 	0.1 C	 	 	0.1 C	 	 		

Thiobis(6-tert-butyl-m-cresol) 4,4'-	96-69-5	HPV	5 and 15	5 and 10	5
(resp), 10 (total)	 	 	 		

Thioglycolic acid	68-11-1	HPV	 	1	1	 	 	 		

Thiram	137-26-8	HPV	5	5	5	 	1	2 ST		

Tin - Inorganic compounds (as Sn)	7440-31-6	 	2	0.1	2	 	 	 		

Tin - Metal	7440-31-5	 	2	 	2	 	 	 		

Tin - Organic compounds (as Sn)	7440-31-6	 	0.1	0.1	0.1	 	 	 	


Tin dioxide (as Sn)	18282-10-5	 	 	 	2	 	 	 		

Titanium tetrachloride	7550-45-0	 	 	 	 	 	 	 		

Tolidine o-	119-93-7	 	 	 	 	0.02 C (60-min)	 	 		

Toluene	108-88-3	HPV	200	50 and 500C	100	150 ST	50	200 ST		

Toluene-2,4-diamine	95-80-7	HPV	 	 	 	 	 	 		

Toluene-2,4-diisocyanate [2,4-TDI]	584-84-9	HPV	0.02 C	0.005 and 0.02 C
 	 	 	 		

Toluenediamine - Mixed isomers	25376-45-8	HPV	 	 	 	 	 	 		

Toluenesulfonyl chloride p-	98-59-9	 	 	 	 	 	 	 		

Toluidine m-	108-44-1	HPV	 	2	 	 	 	 		

Toluidine o-	95-53-4	HPV	5	2	 	 	 	 		

Toluidine p-	106-49-0	HPV	 	2	 	 	 	 		

Tributyl phosphate	126-73-8	HPV	5	0.2	2.5	 	11	44 ST		

Tributyl tin benzoate (as TBTO)	4342-36-3	 	 	 	 	 	0.0021	 	


Tributyltin fluoride (as TBTO)	1983-10-4	 	 	 	 	 	0.0021	 	


Tributyltin linoleate (as TBTO)	24124-25-2	 	 	 	 	 	0.0021	 	


Tributyltin methacrylate (as TBTO)	2155-70-6	 	 	 	 	 	0.0021	 
	

Tributyltin naphthenate (as TBTO)	85409-17-2	 	 	 	 	 	0.0021	 
	

Trichloro-1,2,2-trifluoroethane [FC-113] 1,1,2-	76-13-1	HPV	1000	1000
and 2000 C	1000	1250 ST	500	1000 ST		

Trichloroacetic acid	76-03-9	 	 	1	1	 	 	 		

Trichlorobenzene - All isomers	12002-48-1	 	 	 	 	 	5	10 ST		

Trichlorobenzene 1,2,3-	87-61-6	HPV	 	 	 	 	5	10 ST		

Trichlorobenzene 1,3,5-	108-70-3	 	 	 	 	 	5	10 ST		

Trichloroethane 1,1,2-	79-00-5	HPV	10	10	10	 	10	20 ST		

Trichloroethylene	79-01-6	HPV	100	25 and 300 C	25	2 C (60-min)	 	 	


Trichlorofluoromethane [FC-11]	75-69-4	HPV	1000	1000 C	 	1000 C	1000
2000 ST		

Trichloronaphthalene	1321-65-9	 	5	5	5	 	 	 		

Trichlorophenoxyacetic acid] 2,4,5-T [2,4,5-]	93-76-5	 	10	10	10	 	10
20 ST		

Trichloropropane 1,2,3-	96-18-4	HPV	50	10	10	 	 	 		

Trichlorosilane	10025-78-2	 	 	 	 	 	 	 		

Triethanolamine	102-71-6	HPV	 	5	 	 	 	 		

Triethoxysilane	998-30-1	 	 	 	 	 	 	 		

Triethylamine	121-44-8	HPV	25	1C	 	 	1	2 ST		

Triethylene glycol diacrylate	1680-21-3	 	 	 	 	 	 	 		

Triethylenetetramine	112-24-3	HPV	 	 	 	 	 	 		

Trifluorobromomethane [F-13B1]	75-63-8	HPV	1000	1000	1000	 	1000	8000
ST		

Trifluoroethane 1,1,1-	420-46-2	 	 	 	 	 	 	 		

Trifluoroethanol 2,2,2-	75-89-8	HPV	 	 	 	 	 	 		

Triglycidyl-s-triazinetrione 1,3,5-	2451-62-9	HPV	 	 	 	 	 	 	


Trimellitic anhydride	552-30-7	HPV	 	0.005 C	0.04	 	0.04	 		

Trimethoxysilane	2487-90-3	HPV	 	 	 	 	 	 		

Trimethyl benzene - Mixed isomers	 	 	 	 	 	 	20	40 ST		

Trimethyl benzene [Mesitylene] 1,3,5-	108-67-8	HPV	 	 	25	 	20	40 ST
	

Trimethyl benzene 1,2,3-	526-73-8	 	 	 	25	 	20	40 ST		

Trimethyl benzene 1,2,4-	95-63-6	HPV	 	 	25	 	20	40 ST		

Trimethyl phosphite	121-45-9	HPV	 	2	2	 	 	 		

Trimethylamine	75-50-3	HPV	 	5	 	 	 	 		

Trimethylchlorosilane	75-77-4	HPV	 	 	 	 	 	 		

Trimethylolpropane triacrylate	15625-89-5	HPV	 	 	 	 	 	 		

Trimethylolpropane trimethacrylate	3290-92-4	HPV	 	 	 	 	 	 	


Tri-n-butyltin chloride (as TBTO)	1461-22-9	HPV	 	 	 	 	0.0021	 
	

Tri-n-butyltin)oxide [TBTO] (as TBTO) bis(	56-35-9	HPV	 	 	 	 
0.0021	 		

Trinitrotoluene [TNT] 2,4,6-	118-96-7	 	1.5	0.5	0.5	 	 	 		

Triorthocresyl phosphate	78-30-8	 	0.1	0.1	0.1	 	 	 		

Triphenyl amine	603-34-9	 	 	5	5	 	 	 		

Triphenyl phosphate	115-86-6	HPV	3	3	3	 	 	 		

Tungsten - Insoluble compounds (as W)	7440-33-7	 	 	1 and 5	5	10 ST	 
 		

Tungsten - Metal	7440-33-7	 	 	1 and 5	5	10 ST	 	 		

Tungsten - Soluble compounds (as W)	7440-33-7	 	 	5	1	3 ST	 	 	


Tungsten carbide - Containing > 0.3% nickel, as Ni	12070-12-1	 	 	 
0.015	 	 	 		

Tungsten carbide - Containing > 2% cobalt, as Co	12070-12-1	 	 	 
0.05	 	 	 		

Turpentine	8006-64-2	HPV	100	100	100	 	 	 		

Uranium - Compounds (as U)	7440-61-1	 	 	0.05 and 0.2	 	 	 	 	


Uranium (Natural) - Insoluble compounds (as U)	7440-61-1	 	0.05	0.05
and 0.2	0.2	0.6 ST	0.2	0.4 ST		

Uranium (Natural) - Soluble compounds (as U)	7440-61-1	 	0.25	0.05 and
0.2	0.05	 	 	 		

Urea	57-13-6	HPV	 	 	 	 	 	 		

Valeraldehyde n-	110-62-3	HPV	 	50	50	 	 	 		

Vanadium pentoxide - Dust (as V2O5)	1314-62-1	 	0.5 C	0.05	 	 	 	 
	

Vanadium pentoxide - Fume (as V2O5)	1314-62-1	 	0.1 C	0.05	 	 	 	 
	

Vanadium pentoxide (as V2O5)	1314-62-1	 	 	0.05	 	 	 	 		

Vegetable oil - Mists	 	 	5 and 15	5 and 10	5 and 10	 	 	 		

Vinyl acetate	108-05-4	HPV	 	10	 	4 C (15-min)	 	 		

Vinyl bromide	593-60-2	 	 	5	 	 	 	 		

Vinyl chloride	75-01-4	HPV	1	1	 	 	 	 		

Vinyl cyclohexene 4-	100-40-3	HPV	 	0.1	 	 	 	 		

Vinyl cyclohexene dioxide	106-87-6	 	 	0.1	10	 	 	 		

Vinyl fluoride	75-02-5	HPV	 	 	1	5 C (15-min)	 	 		

Vinyl toluene [Methyl styrene] - Mixed isomers	25013-15-4	HPV	100	50	100
 	100	200 ST		

Vinylidene chloride	75-35-4	HPV	 	1	 	 	2	4 ST		

Vinylidene fluoride	75-38-7	HPV	 	 	1	5 C (15-min)	 	 		

Vinyltrichlorosilane	75-94-5	HPV	 	 	 	 	 	 		

Warfarin	81-81-2	 	0.1	0.1	0.1	 	0.02	0.16 ST		

Welding fumes - not otherwise specified	 	 	 	5	 	 	 	 		

Wood dust	 	 	 	 	1	 	 	 		

Wood dust - Beech & oak	 	 	 	 	1	 	 	 		

Wood dust - Birch, mahogany, teak, walnut	 	 	 	 	1	 	 	 		

Wood dust - Hardwood	 	 	 	 	1	 	 	 		

Wood dust - Softwood	 	 	 	 	1	 	 	 		

Wood dust - Western red cedar	 	 	 	2.5	1	 	 	 		

Xylene - Mixed isomers	1330-20-7	HPV	 	100 and 300 C	 	 	100	200 ST
	

Xylene m-	108-38-3	HPV	100	 	100	150 ST	100	200 ST		

Xylene o-	95-47-6	HPV	100	 	100	150 ST	100	200 ST		

Xylene p-	106-42-3	HPV	100	 	100	150 ST	100	200 ST		

Xylidine - Mixed isomers (Vapor & aerosol)	1330-73-8	 	5	 	2	 	 	 
	

Yttrium - Compounds (as Y)	7440-65-5	 	1	1	1	 	 	 		

Yttrium - Metal	7440-65-5	 	1	1	1	 	 	 		

Zinc beryllium silicate (as Be)	39413-47-3	 	0.002	 	 	0.005 C	 	 
	

Zinc chloride - Fume	7646-85-7	 	1	1	1	2 ST	 	 		

Zinc chromate (as Cr)	13530-65-9	 	0.1 C	0.01	0.001	 	 	 		

Zinc oxide - Dust	1314-13-2	 	5 and 15	5 and 10	5	15 C	 	 		

Zinc oxide - Fume	1314-13-2	 	5	5 and 10	5	10 C	1 (resp)	1 ST (resp)
	

Zinc potassium chromate (as Cr)	11103-86-9	 	0.005	0.005	0.01	 	 	 
	

Zinc stearate	557-05-1	HPV	5 and 15	10	5 and 10	 	 	 		

Zinc yellow (as Cr)	37300-23-5	 	 	0.01	 	 	 	 		

Zirconium - Compounds (as Zr)	7440-67-7	 	5	5	5	10 ST	 	 		

Zirconium - Elemental	7440-67-7	 	 	5	 	 	1	 		

Zirconium - Insoluble compounds (as Zr)	7440-67-7	 	 	5	 	 	1	 	




  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=OSHACT&p_
id=3360"
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=OSHACT&p_i
d=3360  

 TLV’s and Other Consensus Standards - Can OSHA enforce them?
(AIHA®-ASSE)

 HYPERLINK
"http://www.aiha.org/localsections/html/potche/news/AIHA_ASSE_Presentati
on_Consensus_Standards%20b.pdf"
http://www.aiha.org/localsections/html/potche/news/AIHA_ASSE_Presentatio
n_Consensus_Standards%20b.pdf  

 AIHA®'s White Paper on Permissible Exposure Limits

(PELs)   HYPERLINK
"http://www.aiha.org/news-pubs/govtaffairs/Documents/whitepaper02_PELs.p
df"
http://www.aiha.org/news-pubs/govtaffairs/Documents/whitepaper02_PELs.pd
f  

 This policy applies to all workplace hazards, including carcinogens,
and is responsive to Section 20(a)(3) of the Occupational Safety and
Health Act of 1970, which charges NIOSH to “. . .describe exposure
levels that are safe for various periods of employment, including but
not limited to the exposure levels at which no employee will suffer
impaired health or functional capacities or diminished life expectancy
as a result of his work experience.”

 Mixie was developed by the Canadian L'Institut de Recherche
Robert-Sauvé en Santé et en Sécurité du Travail (IRSST) and is
available at:  HYPERLINK
"http://www.irsst.qc.ca/en/-tool-mixie-mixtures-of-substances-in-the-wor
kplace-computer-based-tool-for-evaluating-the-chemical-risk-calculation-
of-the-rm.html"
http://www.irsst.qc.ca/en/-tool-mixie-mixtures-of-substances-in-the-work
place-computer-based-tool-for-evaluating-the-chemical-risk-calculation-o
f-the-rm.html 

  HYPERLINK "http://www.cdc.gov/niosh/topics/ctrlbanding/"
http://www.cdc.gov/niosh/topics/ctrlbanding/  

  HYPERLINK "http://www.hse.gov.uk/coshh/essentials/index.htm"
http://www.hse.gov.uk/coshh/essentials/index.htm  

 ACGIH® (2011): TLVs® and BEIs® Based on the Documentation of the
Threshold Limit Values for Chemical Substances and Physical Agents &
Biological Exposure Indices. American Conference of Governmental
Industrial Hygienists, Cincinnati, Ohio.

 Laszcz-Davis C, Boelter FW, Hearl F, Jayjock M, Perry L, Mclaughlin CF,
O’Reilly M, Radcliffe RT, Stenzel M (2011). Human Health Risk
Assessment. Chapter 18 in Patty’s Industrial Hygiene, 6th Ed., Rose VE
and Cohrssen B, Eds. Wiley, Hoboken NJ.

  HYPERLINK
"http://www.archives.gov/federal-register/codification/executive-order/1
2196.html"
http://www.archives.gov/federal-register/codification/executive-order/12
196.html  

 Criteria for a Recommended Standard:  Occupational Noise Exposure
(1998), NIOSH. http://www.cdc.gov/niosh/docs/98-126/pdfs/98-126.pdf

 TABLE 4-4 Worldwide Regulations for Exposures to Hazardous Noise in the
Workplace, Technology for a Quieter America, National Academy of
Engineering.

http://www.nap.edu/openbook.php?record_id=12928&page=34

 Approaches to Safe Nanotechnology, 2005, NIOSH.  HYPERLINK
"http://www.cdc.gov/niosh/docs/2009-125/pdfs/2009-125.pdf"
http://www.cdc.gov/niosh/docs/2009-125/pdfs/2009-125.pdf  

  HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2011-05-17/pdf/2011-11965.pdf" \l
"page=1"
http://www.gpo.gov/fdsys/pkg/FR-2011-05-17/pdf/2011-11965.pdf#page=1  

 Musculoskeletal Disorders and the Workplace: Low Back and Upper
Extremities (2001) Institute of Medicine (IOM)

  HYPERLINK "http://www.dtic.mil/whs/directives/corres/pdf/605501p.pdf"
http://www.dtic.mil/whs/directives/corres/pdf/605501p.pdf 

  HYPERLINK
"http://www.nrc.gov/about-nrc/state-tribal/agreement-states.html"
http://www.nrc.gov/about-nrc/state-tribal/agreement-states.html  

  HYPERLINK "http://www.osha.gov/SLTC/heatillness/edresources.html"
http://www.osha.gov/SLTC/heatillness/edresources.html  

  HYPERLINK "http://www.osha.gov/SLTC/heatillness/index.html"
http://www.osha.gov/SLTC/heatillness/index.html  

  HYPERLINK "http://www.osha.gov/SLTC/heatstress/index.html"
http://www.osha.gov/SLTC/heatstress/index.html  

  HYPERLINK "http://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_4.html"
http://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_4.html  

 Army TB MED 507, Heat Stress Control and Heat Casualty Management, 
HYPERLINK
"http://phc.amedd.army.mil/topics/discond/hipss/Pages/HeatInjuryPreventi
on.aspx"
http://phc.amedd.army.mil/topics/discond/hipss/Pages/HeatInjuryPreventio
n.aspx  

  HYPERLINK "http://www.cdc.gov/niosh/86-113.html"
http://www.cdc.gov/niosh/86-113.html  

  HYPERLINK
"http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FACT_SHEE
TS&p_id=186"
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FACT_SHEET
S&p_id=186  

  HYPERLINK "http://www.cdc.gov/niosh/topics/coldstress"
http://www.cdc.gov/niosh/topics/coldstress  

  HYPERLINK
"http://phc.amedd.army.mil/topics/discond/cip/Pages/ColdCasualtiesInjuri
es.aspx"
http://phc.amedd.army.mil/topics/discond/cip/Pages/ColdCasualtiesInjurie
s.aspx  

Page   PAGE  5  of   NUMPAGES   54 

 CAS Registry:  HYPERLINK
"http://www.cas.org/expertise/cascontent/registry/index.html"
http://www.cas.org/expertise/cascontent/registry/index.html 

 HPV Chemical Hazard Characterizations:  HYPERLINK
"http://iaspub.epa.gov/oppthpv/hpv_hc_characterization.get_report?doctyp
e=2"
http://iaspub.epa.gov/oppthpv/hpv_hc_characterization.get_report?doctype
=2 

 Title 29, Code of Federal Regulations (CFR) 1910, Occupational Safety
and Health Standards, Subpart Z, Toxic and Hazardous Substances: 
HYPERLINK
"http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS
&p_id=10147"
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&
p_id=10147 

 California Code of Regulations, Title 8, Section 5155. Airborne
Contaminants. Table AC-1 Permissible Exposure Limits For Chemical
Contaminants:  HYPERLINK
"http://www.dir.ca.gov/title8/5155table_ac1.html"
http://www.dir.ca.gov/title8/5155table_ac1.html 

 NIOSH Pocket Guide to Chemical Hazards:  HYPERLINK
"http://www.cdc.gov/niosh/npg/pgintrod.html"
http://www.cdc.gov/niosh/npg/pgintrod.html 

 Short Term/Ceiling

 Deutsche Forschungsgemeinschaft (German Research Foundation, DFG),
.Maximale Arbeitsplatz-Konzentrationen, MAK-Collection for Occupational
Health and Safety, 2010. More information at:  HYPERLINK
"https://webmail.osha.gov/exchweb/bin/redir.asp?URL=http://osha.europa.e
u/en/topics/ds/oel/members.stm" \t "_blank"
http://osha.europa.eu/en/topics/ds/oel/members.stm 

 Millions of particles per cubic foot of air, based on impinger samples
counted by light-field techniques

