California is considering a significant change in the lead
standard. Please review all these documents. If you can
add other items please contact Dan Napier, CIH at 800-644-1924 X 103
or email him at dan@cihcsp.com, but a phone call is advised
This
is a very technical objection to the toxicologists discussion of
possible impacts of low level exposure.
The Linear Non-Threshold (LNT) dose-response model is a commonly
used model in radiation protection that predicts the health risks
associated with low doses of ionizing radiation. The LNT model
assumes that there is no safe threshold dose for radiation exposure
and that even very low doses of radiation can increase the risk of
cancer and other radiation-related health effects.
The LNT model is based on the idea that radiation-induced DNA damage
is cumulative and that any additional damage increases the risk of
cancer. The model assumes that the risk of cancer is directly
proportional to the amount of radiation received, regardless of the
dose level. In other words, the risk of cancer increases linearly
with increasing radiation dose, without any threshold dose below
which there is no risk.
The LNT model has been used as the basis for setting radiation
exposure limits and guidelines for occupational and public radiation
protection. However, it is also a topic of ongoing debate and
controversy in the scientific community, with some researchers
suggesting that the model may overestimate the risks of low-dose
radiation exposure.
Critics of the LNT model argue that it is not based on direct
evidence and that the risks of low-dose radiation exposure may be
overestimated. Some studies have suggested that low doses of
radiation may even have a protective effect against cancer, a
phenomenon known as radiation hormesis. Nevertheless, the LNT model
remains the default model for radiation protection and is widely
used by regulatory agencies and researchers in the field.
In short the data is not conclusive and we should not be spending as
much on the possible benefits of suspect data.
DTSC has gone on with the very low lead levels in spite of some very
concise and clear criticism of the method that they have used to
define lead content.
The CIHC has commented on the new standard, however they left out
the fact that they did nothing to keep the CIH as a competent
professional..See Howard Spielman's letter.
Greetings Everyone -
During the February 15, 2024 Cal/OSHA Standards Board Meeting, the
Standards Board voted to approve the Proposed Amendments to the
Cal/OSHA Lead Standards (8 CCR §1532.1 for Construction Safety and
§5198 for General Industry) and related Permissible Exposure Limit
in the Airborne Contaminants Standard (8 CCR §5155).
The newly approved Proposed Changes are intended to further protect
workers from lead exposure, targeting requirements that are
anticipated to result in lower blood lead levels for workers and
reduce the number of workers who are exposed to elevated levels of
lead in the workplace.
Some of the key changes include:
• Reduction of the lead Permissible Exposure Limit from 50 ug/m3 to
10 ug/m3 (exception for abrasive blasting at 25 ug/m3)
• Reduction of the lead Action Level from 30 ug/m3 to 2 ug/m3
• Implementation of trigger task Levels (Levels 1-3), which presume
exposure over the PEL until an exposure assessment is performed
• Required shower facilities (previously only handwashing) based on
certain criteria
• Expanded requirements for blood lead testing for employees who
work with lead and changes to the frequency of monitoring based on
exposure/air monitoring results
• Medical surveillance for all employees who perform trigger tasks
in addition to confirmed lead-exposed employees
• Expanded medical removal requirements and return to work criteria
based on blood lead testing results
The Proposed Changes were approved by the Cal/OSHA Standards Board
(5 ayes, 2 nays) and will be enacted on January 1, 2025.
The full Proposed Changes language can be accessed here
https://www.dir.ca.gov/oshsb/documents/Lead-txtbrdconsider.pdf
The Final Statement of Reasons (including response to submitted
comments) can be accessed here
https://www.dir.ca.gov/oshsb/documents/Lead-FSOR.pdf
All the Best -
Roxanne Fynboh
Secretary, CIHC Board of Directors