Should OSHA Update Regulations of Chemical Sterilants?

The first and most obvious reason why OSHA should update its regulations is to increase employee safety. Since the federal permissible exposure limits were first promulgated in 1971, new data has emerged about both the short and long-term effects of exposure to chemical sterilants, and this new data should be reflected in the OSHA standards. One of the reasons that many hospitals are phasing Ethylene Oxide (EtO) out of their sterile processing is that the risks associated with EtO are very well known (carcinogen, mutagen, spontaneous abortions, etc). As EtO is phased out, alternatives like hydrogen peroxide, ozone, and peracetic acid are often thought to cause fewer health risks in part because the regulations concerning them are less specific than those that regulate the use of EtO. However, these chemicals can be just as, if not more, dangerous than EtO.

With the exception of a few standards for carcinogenic compounds like EtO, the OSHA PELs of today are largely unchanged from when they were first adopted from the ACGIH TLV values back in 1972. The OSHA PELs should be updated to reflect the new chemical hygiene information of almost four decades and new chemicals used in the work place. If OSHA were to update their regulations reflecting that fact, hospitals would likely be more educated and responsible with their use as the transition to such alternatives continues.

Consistent OSHA enforcement of their regulations is equally important for ensuring workplace safety. A study conducted in 2004 that was published in the American Journal of Public Health followed long-term EtO exposure trends in US hospitals and its relationship with OSHA regulatory and enforcement actions. The study found that exposures declined steadily for the first several years after OSHA set new standards and measurement and monitoring increased. Between 1996 and 2004, however, the probability of exceeding the short-term exposure limit increased while measuring and monitoring decreased, coinciding with a decline in enforcement of the EtO standard. The study’s conclusion states that the data “indicates the need for renewed regulatory and other intervention efforts to protect healthcare workers from EtO’s carcinogenic, allergic-sensitizing, reproductive, and other hazards.” We argue that the same logic applies to other chemical sterilants in addition to EtO. Furthermore, as the study suggests, updated regulations alone would not automatically reduce the risk of worker exposure; enforcement is equally as important.

In summary, to improve workplace safety for those who use chemical sterilants in healthcare, we need to have updated regulations that reflect the current chemicals used and the current knowledge of their exposure risks and consistent enforcement of those regulations. Thus, while proper regulations and enforcement are important, what actually protects employees is having all parties concerned focusing on creating and maintaining a safe work environment, meeting the regulations, providing the engineering controls (ventilation, continuous gas monitors etc), using the personal protective equipment, and developing and using good work practices.

For more information about the American Journal of Public Health study, visit:
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1448503/pdf/0941614.pdf