What is an OSHA PEL in Healthcare?
An OSHA PEL in healthcare is the Permissible Exposure Limit allowed by the Occupational Safety and Health Administration (OSHA) for hazardous substances found in healthcare environments. Most commonly, an OSHA PEL in healthcare will limit employee exposure to hazards such as:
- Ethylene Oxide
- Formaldehyde
- Glutaraldehyde
- Ionizing Radiation
- Laboratory Chemicals
- Antineoplastic Drugs
OSHA sets PELs to protect employees against the health effects of exposure to hazardous substances. Most OSHA PELs in healthcare apply limits to the amount or concentration of a hazardous substance an employee can be exposed to over a period of time.
Typically, an OSHA PEL in healthcare is based on a Time Weighted Average (TWA) for an eight-hour workday or a forty hour work week. Once the exposure limit has been reached, an employee must not be exposed to the hazard for the rest of the day/week.
For some PELs, OSHA also applies Short Term Exposure Limits (STELs) for a higher level of exposure to a hazardous substance than allowed by a TWA for a shorter period of time. For example, the OSHA PEL for exposure to formaldehyde (OSHA §1910.1048(c)) states:
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1910.1048(c)(1)
TWA: The employer shall assure that no employee is exposed to an airborne concentration of formaldehyde which exceeds 0.75 parts formaldehyde per million parts of air (0.75 ppm) as an 8-hour TWA.
1910.1048(c)(2)
STEL: The employer shall assure that no employee is exposed to an airborne concentration of formaldehyde which exceeds two parts formaldehyde per million parts of air (2 ppm) as a 15-minute STEL.
Potential Changes to OSHA Permissible Exposure Limits
The current list of OSHA PELs for hazardous substances and laboratory chemicals can be found in Annotated Tables Z-1, Z-2, and Z-3. The OSHA PEL for ionizing radiation can be found in OSHA §1910.1096. OSHA defers to NIOSH guidelines for occupational exposure to antineoplastic drugs due to the number of neoplastic drugs and the different levels of risk between unopened, intact tablets and capsules and injectable drugs – which usually require extensive preparation.
However, in the preamble to the Annotated Tables, OSHA acknowledges many of its PELs are out of date because they were adopted after the creation of the Administration in 1971 and have not been updated since. Although the current list is the list against which OSHA compliance is assessed, OSHA advises businesses to refer to Cal/OSHA’s more stringent PELs and NIOSH’s “Pocket Guide to Chemical Hazards” and apply the lowest permissible exposure limit.
The reason why there may be changes to OSHA’s PELs is that the Administration has been looking at ways to keep pace with changes to chemical structures and the hazards that exist because of the changes. Acknowledging that the one-chemical-at-a-time approach is not effective, OSHA has proposed adopting a method similar to the EU’s REACH program which moves the burden of developing PELs for hazardous substances from the government to the manufacturer.
How to Comply with an OSHA PEL in Healthcare
The purpose of an OSHA PEL in healthcare is to keep employees safe. If a highly trained employee develops an illness or health condition due to over-exposure to a hazardous substance, the highly trained employee will no longer be able to provide a service for an employer.
Therefore, it is advisable to conduct a risk assessment for all hazardous substances that employees may be exposed to and, where a risk of exposure exists, implement engineering controls, conduct regular air monitoring, and provide PPE and employee training to comply with the OSHA PEL.
Healthcare organizations can be fined – and have been fined – for violating OSHA permissible exposure limits in healthcare; although, over the past year, more healthcare organizations have been cited for failing to communicate hazards than exceeding permissible exposure limits.
If your organization has concerns it is failing to comply with an OSHA PEL in healthcare, or needs help organizing a training or hazard communication program, you should speak with an OSHA compliance expert or approach OSHA directly to see if you qualify for a free onsite consultation.
