Why are you telling me about CAL/OSHA PEL’s? 
      Part II Potential Impacts
  Barbara Kanegsberg and Ed Kanegsberg, SQRC
    Gee, maybe we shouldn’t tell you. Think of the potential fees we could
    collect by watching you dance the “Funky Chicken” trying to cope
    with really, really low PEL’s. Hmmm…. Darn, those annoying ethics – ok,
  here’s more information about the consequences.
  The lower PEL’s can negatively impact quality, including product quality,
      worker safety, and environmental quality. What should you do? Get involved;
      speak up. Support the positive aspects of the new PEL policy so you can
  protect your workers, the environment, and your business.
    Consequences: Decreased worker safety and environmental quality
  With the need for increased process and personnel monitoring, of course,
        lower PEL numbers would cost more to businesses and would negatively
      impact the competitive
        position relative to businesses outside of California. And, in the absence
        of Federal standards, California PEL’s might be adopted by some companies
        outside of California, so competitiveness and profitability could be impacted
        nationwide.
  
The exceedingly low PEL’s may be so difficult to achieve as to impel process and chemical changes. Quality, including not only product quality but more importantly worker safety, community safety, and environmental quality could also be negatively impacted in several ways.
    • Increased use of uncharacterized chemicals
  There is a lot to be said for understanding the risks of a particular chemical.
          However, statements of N.D. (not determined) for worker safety are
    often erroneously taken to mean no risk. In attempting to find viable process
        options, it is
          likely that companies will increase their use of chemicals that are
    not
        well characterized and are not widely used. These chemicals, if they
    are at all
          effective in a given process, are likely to negatively impact the worker
  and the environment. 
  The PEL revision process, while expected to be efficient, will not
            all happen at once. Cal/OSHA will address a few chemicals at a time,
            estimated
            at 12-20
            per year. This means that many chemicals, especially those that are
            less often used or where dangers are not well defined, may be available
            for
            use for quite
  some time before being visited by the “PEL genies”.
  The increased use of poorly–understood, rarely used, and therefore unregulated
              chemicals can negatively impact quality: product quality, worker safety, and
  environmental safety.
    • Increased use of mystery mixes
  When it comes to ingredients, the MSDS does not tell the full story.
  For non-carcinogens, hazardous materials that are less than 1% of the formulation
                  do not normally have to be listed as hazards on the MSDS. This
        has resulted in complex, creative formulation. The Cal/OSHA PEL’s are likely to induce
  additional creativity. 
  What’s the impact on quality? If the blends perform better than the sum
                    of the parts, if there is synergy in cleaning performance, then there is the
                    potential for synergy in a negative sense in terms of materials compatibility
                    (so product quality is impacted), worker safety, and environmental impact.
                    Because typical industrial cleaning formulations of this type are considered
                    proprietary, it is difficult to determine what might be problematic for people,
                    the environment – and even the product. Even without synergy, the additive
                    impact of all the chemicals is potentially significant (i.e. 0.9% + 0.8% +0.95%+ … can
  add up to a significant fraction of a formulation).
    • Increased outsourcing of problematic processes
  If it becomes noisome for California companies to use certain chemicals,
                      the processes are likely to be outsourced to companies
    in other areas that might
                      not have the resources to protect their workers. Pushing
      the broccoli around to another part of the plate (albeit a national or
    international plate) does not resolve the issue. The broccoli (or the contentious
          chemical)
                  is
                    still
                      present; and it can still impact other workers.
  
Product quality can be a safety problem
  Manufacturing involves products with critical end-uses
  for the medical community, defense, and seismic protection.
  We have alluded to the negative impacts on product quality
                          when chemicals or blends with poorly characterized
          properties are
                          adopted without
                          sufficient testing. If manufacturers feel impelled
          to switch from an aggressive,
                          effective cleaning chemistry or other process chemistry,
                          the quality of the surface
                          and
                          the quality of the product can suffer. For products
          with critical end-use requirements, product failure can have
                          serious impacts
                          on public safety
                          and on individual
  safety. 
    • Additional Observation: 
  You might say, “I don’t live or work in California. We have different
                            requirements where I work. Why should I care what happens
  in California?” 
  California PEL’s may come to your state. In today’s economy, manufacturing
                              efforts are linked. It may be that some of your favorite suppliers and sub-vendors
                              are from California. Also, regulators in other areas, often suffering from
                              decreased budgets, look to where a problem has already been addressed—like
                              California. California regulations have been known to
                              influence regulations nationwide; the trend is likely
  to continue.
  So, get involved. How? Read on to Part III.