Implications of OSHA's reliance on TLVs in developing the air contaminants standard

This paper evaluates the decision by the Occupational Safety and Health Administration (OSHA) to base its Air Contaminants Standard on the threshold limit values (TLVs) of the American Conference of Governmental Industrial Hygienists. Contrary to the claim made by OSHA in promulgating the standard, the TLV list was not the sole available basis for a generic standard covering toxic air contaminants. The National Institute for Occupational Safety and Health (NIOSH) presented data indicating that the TLVs were insufficiently protective for 98 substances. NIOSH Recommended Exposure Limits (RELs) were available for 59 of these substances. The ratio of PEL to REL ranged up to 1,000, with a median of 2.5 and a mean of 71.4. OSHA excluded 42 substances from the standard altogether despite the availability of NIOSH RELs, solely because no TLV had been established.     

Skin notation in the context of workplace exposure standards

In the establishment of workplace exposure standards, the potential for cutaneous absorption is taken into consideration through the addition of "skin notation" to the relevant substance. In the TLVs Documentation (ACGIH, 1986) dermal lethal dose to 50% (LD50) or human data are the bases for the assignment of "skin notation" to 91 of 168 substances. For the other substances, the "skin" attribution seems to be based on undocumented statements in 24 (14.5%), skin effects in 13 (8%), and analogy in 7 (4%), while in the remaining 33 (20%) any reference is lacking as to the basis for notation of the cutaneous route of entry. Furthermore, since the established "cut-off" value of 2 g/kg is sometimes bypassed when a notation is added or omitted, the use of dermal LD50 is perplexing. Given the relevance of the skin notation for the validation of threshold limit values (TLVs) in the workplace, a full examination and citation of all available scientific data are recommended when establishing the TLV of substances absorbable through the skin.     

The role of threshold limit values in U.S. air pollution policy.

This paper analyzes the role of threshold limit values (TLVs) in national air pollution policy during the 1980s, a period in which the Environmental Protection Agency (EPA) sought to delegate to individual states the authority to evaluate and regulate airborne toxic substances. We focus on 20 carcinogens and 11 substances with non-genotoxic health effects that were regulated by local air toxics programs using TLVs. Data from EPA's National Air Toxics Information Clearinghouse indicate that maximum TLV-based Ambient Air Level guidelines (AALs) frequently exceed minimum TLV-based AALs by a factor of greater than 1,000. Cancer potency data from EPA's Integrated Risk Information System suggest significant risks remain at TLV-based AALs. Cancer risks at the median TLV-based AAL exceed 1,000 cases per million exposed persons for cadmium (1,040), nickel and its compounds (1,420), propylene oxide (1,550), coke oven emissions (1,860), benzene (2,500), arsenic and its compounds (7,300), N-nitrosodimethylamine (21,000), asbestos (21,500), and ethylene dibromide (55,000). We also summarize published studies that report non-genotoxic health effects in workers exposed at levels near the TLV for 11 substances whose AALs were based on TLVs. Contrary to the assumption frequently made by state air toxics program, TLVs cannot be taken to represent no observed effect levels (NOELs) for regulatory purposes.     

Evaluation of employee exposure to organic tin compounds used as stabilizers at PVC processing facilities

Organic tin compounds are primary substances used as heat stabilizers by the polyvinyl chloride (PVC) industry. The use of these compounds in the PVC industry is generally well controlled, usually by automated processes. This study was conducted to provide an overview of worker exposure to organic tin compounds at PVC processing facilities and to verify that these exposures are below the threshold limit value (TLV((R))) set by the American Conference of Governmental Industrial Hygienists for organic tin. The basis of the TLV indicates the principal concern is to minimize adverse effects on immune function and the central nervous system from airborne exposure to organic tin. The TLV has a skin designation based on the potential for percutaneous absorption; the TLVs for inhalation exposures are based on the presumption that there is no concurrent exposure via the skin and oral ingestion routes.Personal exposure monitoring was conducted following the National Institute for Occupational Safety and Health (NIOSH) 5504 sampling method and a modified version of the NIOSH analytical method. The results were reported as"total tin."The data indicated no average exposure levels for individual tasks exceeded the organic tin TLV, and 96%of results the samples were less than 20%of the TLV. Only 1 sample of 102 exceeded the TLV, and the individual was wearing appropriate respiratory protection. Subsequent investigation indicated the highest exposures occurred while the operators were conducting tasks that included manual handling of the organic tin compounds. These data suggest manual operations may have a greater potential for organic tin exposure.     

But they are not thresholds: A critical analysis of the documentation of threshold limit values

Threshold Limit Values (TLVs) represent conditions under which the TLV Committee of the American Conference of Governmental Industrial Hygienists (ACGIH) believes that nearly all workers may be repeatedly exposed without adverse effect. A detailed research was made of the references in the 1976 Documentation to data on “industrial experience” and “experimental human studies.” The references, sorted for those including both the incidence of adverse effects and the corresponding exposure, yielded 158 paired sets of data. Upon analysis it was found that, where the exposure was at or below the TLV, only a minority of studies showed no adverse effects (11 instances) and the remainder indicated that up to 100% of those exposed had been affected (8 instances of 100%). Although, the TLVs were poorly correlated with the incidence of adverse effects, a surprisingly strong correlation was found between the TLVs and the exposures reported in the corresponding studies cited in the Documentation. Upon repeating the search of references to human experience, at or below the TLVs, listed in the more recent, 1986 edition of the Documentation, a very similar picture has emerged from the 72 sets of clear data which were found. Again, only a minority of studies showed no adverse effects and TLVs were poorly correlated with the incidence of adverse effect and well correlated with the measured exposure. Finally, a careful analysis revealed that authors' conclusions in the references (cited in the 1976 Documentation) regarding exposure-response relationships at or below the TLVs were generally found to be at odds with the conclusions of the TLV Committee. These findings suggest that those TLVs which are justified on the basis of “industrial experience” are not based purely upon health considerations. Rather, those TLVs appear to reflect the levels of exposure which were perceived at the time to be achievable in industry. Thus, ACGIH TLVs may represent guides of levels which have been achieved, but they are certainly not thresholds.     

Assessing the health implications for healthcare workers of regulatory changes eliminating locally developed occupational exposure limits in favor of TLVs: an evidence-based bipartite approach

In response to the intention of the Workers' Compensation Board of British Columbia (WCB of BC) to eliminate made-in-BC occupational exposure limits (OELs) and adopt threshold limit values (TLVs), this study assessed the potential health impacts on healthcare workers (HCWs) of the proposed change, by (1) reviewing the processes used to establish the OELs and TLVs, (2) selecting of substances of health concern for HCWs, (3) identifying chemicals with discordances between existing OELs and the 2002 TLVs, and 4) reviewing the discordances and assessing the potential health implications. Differences in philosophies, policies and processes that influenced the setting of OELs and TLVs were substantial. The TLV process involves U.S. and international priorities; in BC, a tripartite committee determined OELs taking into consideration how OELs should be interpreted in the local context. 47 chemicals of concern to BC HCWs were discordant, with significant discordances totalling 57; 15 compounds had BC 8-hour OELs lower than their respective TLVs and three TLVs were lower than the 8-hour BC OELs. Review of six chemicals with discordances suggested a potential for increased risks of adverse health effects. Eliminating the local capacity and authority to set OELs is unlikely to cause major health problems in the short run, but as chemicals in use locally may not have up-to-date TLVs, eliminating the capacity for local considerations should be undertaken with great caution. While the WCB of BC did implement the change, the present report resulted in procedural changes that will provide better protection for the workforce.     

The impact of a change to inhalable occupational exposure limits: strontium chromate exposure in the U.S. Air Force

The American Conference of Governmental Industrial Hygienists has announced its intention to replace all total particulate threshold limit values (TLVs) with size-selective TLVs. Because the U.S. Air Force has adopted the TLVs as its occupational exposure limits, the impact of this change is of interest, specifically for hexavalent chromium. This article reviews historical strontium chromate sampling data in the Air Force and the impact of its reinterpretation in comparison to an inhalable TLV. Based on the measured conversion factor between the 37-mm cassette and the IOM inhalable sampler, inhalable strontium chromate exposures will continue to exceed the TLV during all aircraft priming and most sanding procedures. In addition, inhalable exposures are expected to exceed 1000 times the TLV, greater than the highest currently assigned protection factor for airline respirators, during 25% of priming procedures. Without a change in the value of the current TLV time-weighted average of 0.5 microg/m(3), the Air Force will need to reduce strontium chromate levels, either by incorporating work practices that decrease worker productivity or considering a change to nonchromated primers.     

Threshold limit values,permissible exposure limits,and feasibility: The bases for exposure limits in the United States

The development of exposure limits in the United States has always relied heavily upon the threshold limit values (TLVs) developed by the American Conference of Governmental Industrial Hygienists (ACGIH). In fact, the TLVs were adopted as official exposure limits by the Occupational Safety and Health Administration (OSHA) in 1972 and 1989. Given the continuing importance of the ACGIH limits, this paper compares the basis of the TLVs with that employed by OSHA de novo in its 12 new permissible exposure limits (PELs). Using benzene as an example, it is shown that OSHA's new PELs have been established following a rigorous assessment of the inherent risks and the feasibility of instituting the limit. The TLVs, on the other hand, have been developed by ad hoc procedures and appear to have traditionally reflected levels thought to be achievable at the time. However, this might be changing. Analysis of the historical reductions of TLVs, for 27 substances on the 1991–1992 list of intended changes, indicates smaller reductions in the past (median reduction of 2.0–2.5-fold between 1946 and 1988) compared to those currently being observed (median reduction of 7.5-fold between 1989 and 1991). Further analysis suggests a more aggressive policy of the ACGIH regarding TLVs for carcinogens but not for substances that produce effects other than cancer. Regardless of whether the basis of the TLVs has changed recently, it would take a relatively long time for the impact of any change to be felt, since the median age of the 1991–1992 TLVs is 16.5 years, and 75% of these limits are more than 10 years old. The implications of OSHA's continued reliance on the TLVs as a means of updating its PELs are discussed, and four alternatives are presented to the ACGIH regarding the future of its activities related to exposure limits. It is concluded that new mechanisms are needed for OSHA to update its PELs in a timely fashion so that the TLVs will not be adopted by default in the future. © 1993 Wiley-Liss, Inc.     

The beryllium "double standard" standard.

Brush Wellman, the world's leading producer and supplier of beryllium products, has systematically hidden cases of beryllium disease that occurred below the threshold limit value (TLV) and lied about the efficacy of the TLV in published papers, lectures, reports to government agencies, and instructional materials prepared for customers and workers. Hypocritically, Brush Wellman instituted a zero exposure standard for corporate executives while workers and customers were told the 2 microgram standard was "safe." Brush intentionally used its workers as "canaries for the plant," and referred to them as such. Internal documents and corporate depositions indicate that these actions were intentional and that the motive was money. Despite knowledge of the inadequacy of the TLV, Brush has successfully used it as a defense against lawsuits brought by injured workers and as a sales device to provide reassurance to customers. Brush's policy has reaped an untold number of victims and resulted in mass distribution of beryllium in consumer products. Such corporate malfeasance is perpetuated by the current market system, which is controlled by an organized oligopoly that creates an incentive for the neglect of worker health and safety in favor of externalizing costs to victimized workers, their families, and society at large.     

Limitations of occupational air contaminant standards, as exemplified by the neurotoxin N-hexane

Available industry guidelines and federal standards have failed to fully protect workers from chemical toxicity: none exist for most chemicals, many are biased toward what can easily be achieved, and many were developed long after health consequences became evident. Limitations of occupational air contaminant standards in the United States are well illustrated by standard-setting for the neurotoxin n-hexane. In the 1940s, the American Conference of Governmental Industrial Hygienists (ACGIH) first promulgated industrial guidelines known as "threshold limit values" (TLVs), including an 8-hour time-weighted average of 500 ppm for inspired n-hexane. Despite subsequent recognition of the neurotoxicity of n-hexane with industrial outbreaks of polyneuropathy beginning in the 1960s, the TLV for n-hexane remained unchanged until 1976 when a value of 100 ppm was adopted. Because a growing number of clinical reports have identified clinical and subclinical neurotoxicity from n-hexane near, at, and below the current time-weighted average TLV of 50 ppm, even this level is too high to protect all workers. In part due to procedural and political constraints, the Occupational Safety and Health Administration (OSHA) has independently developed only a small number of exposure standards in the past 25 years, and has been incapable of providing needed revisions for existing standards. Most OSHA standards--including those for n-hexane--were adopted in 1971 from the 1968 ACGIH TLVs and have never been revised. From 1971 to 1989 the OSHA permissible exposure level (PEL) for n-hexane remained at 500 ppm, 5-10 times as great as other contemporary standards. To help correct its regulatory backlong, OSHA promulgated 375 new or revised PELs in 1989--including a new standard of 50 ppm for n-hexane--but all of these were vacated by the 11th U.S. Court of Appeals in 1992. As a result, the current OSHA PEL for n-hexane remains at the 500 ppm level adopted in 1971, which even then was too high based upon available scientific evidence. New information over this long period, including that obtained from industrial outbreaks of disease due to chemical exposures, has not been incorporated into revised federal standards.     

Biological monitoring of nitrous oxide exposure in surgical areas

Exposure to nitrous oxide in surgical theaters was evaluated for duration, numbers, and types of surgical procedures. The concentration of the gas in the air was 92-444 ppm. Before and after the surgical sessions, samples of urine and expired air were collected from surgical theater personnel for gas determination. Nitrous oxide concentrations in urine and in expired air showed a good correlation with gas concentration in the air (r = 0.760 and r = 0.921, respectively). Moreover, a good correlation (r = 0.823) between gas concentration in urine and that in expired air was also found. A biological threshold limit value (TLV) of 20.6 micrograms/liter for urine and of 29.6 ppm for expired air was calculated, based on the limit of 50 ppm in the air proposed by the American Conference of Governmental Industrial Hygienists (ACGIH). Other biological TLVs corresponding to higher proposed limits (200 and 500 ppm) were also calculated.     

Identifying an apppropriate occupational exposure limit (OEL) for beryllium: data gaps and current research initiatives

The occupational exposure limit of 2.0 microg/m3 for beryllium has been used in the workplace since the late 1940s. In particular, the adequacy of the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV) for beryllium has recently come into question. The symposium "Beryllium: Effect on Worker Health" was convened in September 1999, to bring together leading scientists to present and discuss current research activities on beryllium exposure and chronic beryllium disease (CBD). One of the key questions to be resolved at the symposium was, "Is there a sufficient understanding of exposure and the cause of CBD that would allow us to develop a TLV that we believe would prevent disease?" Seven scientists presented information regarding the current understanding of the disease, possible causes, and ongoing research. The topics were (1) biomonitoring approaches and their relationship with clinical effects, (2) historical and current exposure assessments, (3) sampling methods and aerosol characterization, and (4) epidemiology. Six basic hypotheses regarding the relationship between exposure to beryllium and CBD were generated from the information presented at the symposium. The six hypotheses that are related to issues such as beryllium form, particle size, industrial hygiene practices, extrapulmonary routes of exposure, and genetic susceptibility also appear to be the focus of ongoing and likely future research initiatives. This article summarizes both the presentations made at the meeting and the hypotheses generated. It is expected that an understanding of these issues should explain the inconsistent dose-response relationship observed between exposure and CBD. The ongoing and planned research is anticipated to provide sufficient data within two to three years to develop one or more scientifically sound TLVs for the different chemical forms of beryllium.     

Evaluation of portable single-gas monitors for the detection of low levels of hydrogen sulfide and sulfur dioxide in petroleum industry environments

Many portable single-gas monitors are used for the detection of low concentrations of hydrogen sulfide (H(2)S) and sulfur dioxide (SO(2)) in the workplace. With the recent lowering of the H(2)S and SO(2) ACGIH? threshold limit value (TLV?) the ability of these devices to selectively respond to these new lower levels is not well documented in petroleum industry environments, which often have potential interfering gases and vapors present as well as varying environmental conditions. Tests were carried out to measure the ability of various monitors with their respective sensors to correctly quantify and respond to H(2)S and SO(2) in a simulated petroleum industry environment. This included the identification of selected interference effects and estimation of the reliable lower limit of detection for real workplace environments. None of the H(2)S monitors responded at 0.1 times the new TLV (0.1 ppm), only some of them responded at the new TLV concentration (1 ppm), and all the monitors exposed to five times the new TLV (5 ppm) responded with reasonable accuracy. There was generally little effect of interferent gases and vapors on the H(2)S monitors. None of the SO(2) monitors responded at 0.1 and 1 times the new TLV (0.025 ppm and 0.25 ppm) concentrations, and all but one of them exposed to five times the new TLV (1.25 ppm) responded. There was much greater cross-sensitivity to interferents at the tested concentrations with the SO(2) monitors, which responded to six out of eight of the interferents tested. Results demonstrate that these monitors cannot reliably alarm and measure H(2)S or SO(2) concentrations at the new TLVs with an acceptable degree of accuracy. However, these monitors are designed to alarm as a safety device; these results do not change this important function.     

A tale of two limits

As they do with other potentially hazardous agents, occupational health and safety professionals in the United States take a two-pronged approach to controlling noise exposure. We assure compliance with OSHA's regulatory limits to satisfy lawyers and compliance officers while using TLVs to protect worker health. Unfortunately, using both the TLV and OSHA limits for noise exposure may involve considerably more work than for most chemical exposures. Using both limits for noise may require different measuring equipment or multiple measurements of exposure. Using the TLV also may require noise measurement at the abdomen, as well as the ear and consideration of concomitant chemical exposures. Finally, using the TLV requires the OHS professional to confront the fact that no exposure value can claim to protect all workers and that employee rotation may result in more hearing loss than would exposing a smaller group of workers to more noise. These facts make it clear why OHS professionals should never use exposure limits as just numbers. Rather, we strive to understand the basis for the limits we are using, to be sure we understand the limitations of those limits and how they might uniquely affect our workers in their work environments.     

The effects of temperature and pressure on airborne exposure concentrations when performing compliance evaluations using ACGIH TLVs and OSHA PELs

Occupational hygienists perform air sampling to characterize airborne contaminant emissions, assess occupational exposures, and establish allowable workplace airborne exposure concentrations. To perform these air sampling applications, occupational hygienists often compare an airborne exposure concentration to a corresponding American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV) or an Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL). To perform such comparisons, one must understand the physiological assumptions used to establish these occupational exposure limits, the relationship between a workplace airborne exposure concentration and its associated TLV or PEL, and the effect of temperature and pressure on the performance of an accurate compliance evaluation. This article illustrates the correct procedure for performing compliance evaluations using airborne exposure concentrations expressed in both parts per million and milligrams per cubic meter. In so doing, a brief discussion is given on the physiological assumptions used to establish TLVs and PELs. It is further shown how an accurate compliance evaluation is fundamentally based on comparison of a measured work site exposure dose (derived from the sampling site exposure concentration estimate) to an estimated acceptable exposure dose (derived from the occupational exposure limit concentration). In addition, this article correctly illustrates the effect that atmospheric temperature and pressure have on airborne exposure concentrations and the eventual performance of a compliance evaluation. This article also reveals that under fairly moderate conditions of temperature and pressure, 30 degrees C and 670 torr, a misunderstanding of how varying atmospheric conditions affect concentration values can lead to a 15 percent error in assessing compliance.     

Evaluation of potential toxicity from co-exposure to three CNS depressants (toluene, ethylbenzene, and xylene) under resting and working conditions using PBPK modeling

Under OSHA and American Conference of Governmental Industrial Hygienists (ACGIH) guidelines, the mixture formula (unity calculation) provides a method for evaluating exposures to mixtures of chemicals that cause similar toxicities. According to the formula, if exposures are reduced in proportion to the number of chemicals and their respective exposure limits, the overall exposure is acceptable. This approach assumes that responses are additive, which is not the case when pharmacokinetic interactions occur. To determine the validity of the additivity assumption, we performed unity calculations for a variety of exposures to toluene, ethylbenzene, and/or xylene using the concentration of each chemical in blood in the calculation instead of the inhaled concentration. The blood concentrations were predicted using a validated physiologically based pharmacokinetic (PBPK) model to allow exploration of a variety of exposure scenarios. In addition, the Occupational Safety and Health Administration and ACGIH occupational exposure limits were largely based on studies of humans or animals that were resting during exposure. The PBPK model was also used to determine the increased concentration of chemicals in the blood when employees were exercising or performing manual work. At rest, a modest overexposure occurs due to pharmacokinetic interactions when exposure is equal to levels where a unity calculation is 1.0 based on threshold limit values (TLVs). Under work load, however, internal exposure was 87%higher than provided by the TLVs. When exposures were controlled by a unity calculation based on permissible exposure limits (PELs), internal exposure was 2.9 and 4.6 times the exposures at the TLVs at rest and workload, respectively. If exposure was equal to PELs outright, internal exposure was 12.5 and 16 times the exposure at the TLVs at rest and workload, respectively. These analyses indicate the importance of (1) selecting appropriate exposure limits, (2) performing unity calculations, and (3) considering the effect of work load on internal doses, and they illustrate the utility of PBPK modeling in occupational health risk assessment.     

Regression method to estimate provisional TLV/WEEL-equivalents for non-carcinogens

There is a huge and changing number of chemicals in commerce for which workplace exposure criteria have not been assigned. Assigning an exposure criterion by an expert committee is resource-intensive-not soon available for the large majority of chemicals in current use. In the absence of assigned criteria, we have provided a regression method to estimate a first-screen estimate of a 'TLV/WEEL-equivalent' inhalation time-weighted average exposure criterion for a pure chemical (or chemical group) from a measure of a non-stochastic toxic exposure to elicit a chronic or sub-chronic health effect, known as a lowest observable adverse effect level (LOAEL) or a (highest) no observable adverse effect level (NOAEL). Results are presented for six data sets for which both a threshold limit value (TLV) or workplace environmental exposure level (WEEL) exposure criterion is presently assigned, and a LOAEL or NOAEL measure of toxic health effect was available from the United States Environmental Protection Agency Integrated Risk Information System data base. The results can be applied as a first estimate of exposure to substances for which no TLV or WEEL (TLV/WEEL) exists, and also serve as a mechanism for identifying substances for potential re-evaluation of their exposure limit, based on their relative position about the prediction models.     

A Cross-Sectional Assessment of the ACGIH TLV for Hand Activity Level

The ACGIH Worldwide Threshold Limit Value (TLV) for hand activity considers average hand activity level or HAL and peak hand force. We report cross-sectional data that assess the validity of the TLV with respect to symptoms and selected upper extremity musculoskeletal disorders among workers. The prevalence of symptoms and specific disorders were examined among 908 workers from 7 different job sites in relation to the TLV. Worker exposures were categorized as above the TLV, above the TLV Action Limit but below the TLV, or below the TLV Action Limit. Symptoms in the distal upper extremities did not vary by TLV category. Tendonitis in the wrist/hands/fingers did not vary by TLV category, but elbow/forearm tendonitis was significantly associated with TLV category. All measures of carpal tunnel syndrome were associated with TLV category. In all instances, prevalence of symptoms and specific disorders were substantial in jobs that were below the TLV action limit, suggesting that even at acceptable levels of hand activity, many workers will still experience symptoms and/or upper extremity musculoskeletal disorders, which may be important in the rehabilitation and return to work of injured workers. Future analyses need to examine the incidence of symptoms and upper extremity musculoskeletal disorders prospectively among workers in relation to the TLV for hand activity.     

Biological exposure index of styrene suggested by a physiologico-mathematical model

Summary We used a physiologico-mathematical model to study the biological exposure index of styrene correlated to the Threshold Limit Value (TLV) suggested by the ACGIH for 1986–87. This model allows the solvent concentrations in blood, alveolar air, fat tissue, and in other biological media to be estimated and simultaneously the kinetics of its metabolites to be followed when a specific exposure is settled. The comparison between the results obtained from the mathematical model and the numerous research projects documented in the literature suggests a reciprocal validation. Moreover, some biological parameters (particularly the alveolar ventilation) can explain the variability of results obtained from studies concerning the solvent pollution of the factories, which used biological monitoring. The ranges of styrene concentrations in blood and alveolar air and the urinary concentrations of its metabolites (mandelic and phenylglioxylic acids) are discussed in connection with the exposure at 215 mg/m3. Important differences correlated to the definition of set-levels of TLV and Biological Exposure Index (BEI) have been found: particularly the TLVs lead to different solvent uptakes according to some biological parameters; the BEI can better explain the individual solvent uptake and body burden.     

Odor thresholds and irritation levels of several chemical substances: a review

A collation of odor threshold data for approximately 450 chemical substances is presented. The range of odor thresholds reported in the literature is shown along with any reported threshold of irritation to humans. These data can assist the industrial hygienist in determining when an "odor" may be in excess of the Threshold Limit Value, when an organic vapor respirator is not acceptable due to the lack of an odor warning at the end of a cartridge life, and where odors may not indicate a hazard due to extremely low odor thresholds which may be well below the respective TLVs.