XI. Benefits

OSHA expects these final revisions to the standard to produce quantifiable benefits in the form of reduced cancer incidence due to the lowered PEL and increased training, and reduced acute respiratory irritation due to the institution of medical removal protection. In addition, OSHA expects that the lower PEL and increased training would improve worker productivity through a lessening of irritation and an improved understanding of workplace processes.

Cancers Avoided

An estimated 83,818 workers are currently exposed above 0.75 ppm, at an average formaldehyde concentration of 0.875 ppm. This exposure is expected to be reduced to an average of 0.5625 ppm after implementation of the 0.75 ppm PEL. The 1987 RIA employed a cancer risk model developed by the Consumer Product Safety Commission based upon rat studies [Ex. 206, p. V-1-5]. Based upon this model, OSHA estimates that from 0.2 to 72 cancers would be avoided over the next 45 years by lowering the PEL from 1 to 0.75 ppm, depending on whether the Maximum Likelihood Estimate (MLE) or the Upper Confidence Limit (UCL) is used in the risk assessment(7). Lowering exposure levels should also bring some decrease in respiratory distress and may result in greater worker productivity, as described further below.

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  Footnote(7) Based upon the CPSC five-stage model, the Maximum Likelihood
Estimate of Risk (MLE) is expressed as:
  EP(d) = 0.3954763163 X 10(-5) X (dose in ppm)(4) + 0.1597258396 X 10(-5)
X (dose in ppm)(5)
  where
  EP(d) = the excess probability of cancer attributable to formaldehyde
  The Upper Confidence Limit (UCL) is approximately linear at low doses
and, for the purposes of this analysis, could be expressed as:
  EP(d) = 264 X 10(-5) X (dose in ppm).

OSHA believes that the additional training would also provide health benefits. Annual training insures that the knowledge and appreciation of the hazard and ways to limit exposure through good work practices are reinforced continually.

The projected benefits of the hazard communication rule were a 20 percent reduction in all chemically related worker illnesses as the result of labeling, MSDSs and initial training. With the specific exposure reductions noted in the industry discussion, OSHA expects an additional 5 percent reduction in formaldehyde-related illnesses among the workers exposed between 0.1 and 0.5 ppm. Using the same risk model used to project benefits from lowering the PEL, OSHA estimates that, given a 5 percent risk reduction from annual training, an additional .004 to 79 cancers would be avoided over the next 45 years as a result of annual training(8).

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  Footnote(8) This was estimated by using the MLE and the UCL, applied to
all employees exposed to formaldehyde between 0.5 and 0.1 ppm, assuming an
average exposure of 0.3 ppm, and a 5 percent reduction in risk.

In sum, OSHA estimates that lowering the PEL and providing additional training could prevent as many as 151 cancers over the next 45 years based upon the upper confidence limit risk assessment model. However, the maximum likelihood estimate of risk, produces only negligible benefits related to the final revisions.

Non-Carcinogenic Benefits

In the 1987 RIA, OSHA estimated that 5,911 cases of respiratory distress would be eased by lowering the PEL to 1.0 ppm [Ex. 206, p. V-9-11]. These same symptoms persist at very low exposure levels for a small percentage of the population. These employees would be directly aided by medical removal protection.

There are approximately 2,156,801 employees exposed to formaldehyde at 0.1 ppm or greater. As discussed in the 1987 RIA, employee exposure to formaldehyde can cause eye, nose, and throat irritation, coughing, headaches, chest discomfort, changes in lung function, impaired physical performance and exacerbation of asthma. OSHA estimates that as many as 1 percent, or 21,568 workers may be removed annually for respiratory distress. This represents a potential cost savings to society since the protected worker will be more productive when not experiencing health problems.

[57 FR 22290, May 27, 1992]