(Certified Best Practice by BMPCOE)
Polaroid Corporation - Waltham, MA
In 1968, OSHA regulated permissible exposure limits (PELs) for almost 800 chemicals. These PELs, based on an earlier concept established by the American Conference of Governmental and Industrial Hygienists (ACGIH), identify safe worker exposure limits to air contaminants. However, detailed procedure requirements make regulation difficult to modify as new information becomes available. The
National Institute for Occupational Safety and Health (NIOSH) proposes its own limits for chemicals known as Recommended Exposure Limits (RETs). These multiple exposure limits for a given chemical, combined with the trend of tightening environmental regulations, motivated Polaroid to establish its own, very conservative approach for identifying exposure limits.
In the late 1970s, Polaroid developed Polaroid Exposure Guidelines (PEGs) for materials handled in significant quantities based on current literature and toxicity test results from Polaroid-sponsored studies and existing established limits. PEGs are usually set at one-half of the lowest limit of an existing PEL or ACGIH, or less if the Polaroid review team deems it to be prudent. Although PEGs are self-imposed guidelines rather than federally-imposed limits, Polaroid strives to maintain that worker exposure is less than these guidelines. Polaroid's existing site evaluation and monitoring programs verify their compliance with PEGs. If exposures deviate beyond PEG limits, then Polaroid takes prompt corrective action.
If official or unofficial guidelines do not exist, then the PEG is based upon known and suspected toxic effects, governed by a rating system designed for this purpose. Among other advantages, conservative PEGs are used to anticipate downward shifts in the OSHA PELs. Goal setting is straightforward since only one source exists for the guidelines, and no one needs to struggle to meet a more stringent requirement. Polaroid can quickly respond to new test data on exposure hazards as the company has an existing mechanism to incorporate that information with its company policy. This guideline program has existed for more than 15 years and has proven to be a satisfactory mechanism for practicing workers' health protection.