| Abstract |
The testimony concerns the support of NIOSH for the proposed rule on occupational exposure to 4,4'-methylenedianiline (101779) (MDA) put forth by OSHA. Specific issues addressed include biological monitoring, exposure limits, medical surveillance, respiratory protection, chemical protective clothing (Laundering, permeability rates of aprons and other clothing including footwear, signs and labels, visual examination), and the sampling and analytical method. Specific comments were offered on a de minimum exclusion for mixtures of MDA less than 0.1% MDA, the appropriateness of establishing dermal disposition limits and using these limits to define the likelihood of dermal exposure, the establishment of regulated areas, a method for determining that lunch areas are free of MDA contamination, the use material safety data sheets for mixtures containing MDA rather than furnishing employees with such information for MDA only, requirements for medical examinations of workers at specific time intervals, questions concerning the multiple physician review, medical removal benefits with regard to workers' compensation, exemptions for cured comosites, visual monitoring of the skin for MDA exposure, rotation of employees, voluntary use of respirators, and the need for a plain language appendix to facilitate explanation of the standard to workers and nontechnical managers. |
