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Chapter VI of the OSHA Industrial Hygiene Field Operations Manual (4 June 1979) describes the Occupational Safety and Health Administration's (OSHA's) policy and procedures for “documentation of the presence of a toxic material(s) in significant amounts.” The instructions tell the OSHA industrial hygienists to apply wipe sampling procedures to support general duty clause [5(a)(1)] citations for poor work practices. The entire procedure described is not based on sound professional judgment concerning airborne exposures or even potential ingestion of a contaminant. This paper reviews OSHA wipe sampling policies and raises questions about the lack of precise definitions for “presence,” “significant amounts,” and “risk establishment” of toxic materials found on workplace surfaces or protective equipment.
organics, toxic organics, atmosphere wipe sampling
Director, Corporate Safety and Health, Republic Steel Corp., Cleveland, Ohio