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I I I I I I I THEODOR D STERLING AND ASSOCIATES LTD COMMENTS ON THE NOTICE OF PROPOSED RULEMAKING ISSUED BY THE U.S. OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION ADDRESSING INDOOR AIR QUALITY IN INDOOR WORK ENVIRONMENTS Submitted to: Mr. Thomas a i _ _ .OSHA Division of Consumer Affairs Docket No. H-122 I I Prepared by: Theodor D. Sterling James J. Weinkam Wiif L. Rosenbaum August 11th, 1994 ~ 250 • 1122 MAINLAND STREET, VANCOUVER, BRITISH COLUMBIA, CANADA V6B 5L1 (604) 681-2701 FAX (60L) 681-2702

I I I I I I I I I INTRODUCTION The notice of proposed rulemaking issued by the U.S. Occupational Safety and Health Administration on April 5th,1994 (29 CFR, Parts 1910, 1915, 1926 and 1928) proposes the adoption of standards addressing indoor air quality in indoor environments. This notice was published in the Federal Register, _ Vol. 59(65), pages 15968 to 16039. In the summary of the OSHA notice of proposed rulemaking, the following statement is made: "T he Agency invites the submission of written data, views and comments on all regulatory provisions proposed in this notice, and on all relevant issues pertinent to those provfsions." In response to the call for written submissions by OSHA, the enclosed comments have been prepared by Theodor D. Sterling and Associates (TDSA) Ltd., an interdisciplinary research and consulting firm that has provided services on indoor environmental issues since 1973. The more that 100 clients for which TDSA Ltd. have worked include government agencies, labor unions, private sector industry, and building owners and managers. TDSA Ltd staff and consultants have conducted epidemiological research and risk assessments focusing on exposure to substances including formaldehyde, pesticides, dioxins, and environmental tobacco smoke. This submission to OSHA has been prepared by three TDSA Ltd. team members: Dr. Theodor D. Sterling (Staff Member), Dr. James J. Weinkam (Consultant) and Wilf L. Rosenbaum (Consultant). Additional information about TDSA Ltd.'s extensive research and consulting experience and the J qualif cations of the individual team members responsible for the preparation of the comments to OSHA are described in the final section of this document. The submission to OSHA by TDSA Ltd. is organized into three sections, with each section separated by a numbered divider. Sections One and Two provide comments regarding specific components of the proposed rules. Section Three describes the TDSA Ltd. team members' qualifications and experience. The sections are titled as follows: 1. A Critical Examination of the OSHA ETS Risk Assessment. 2. An Alternative Explanation for the Apparent Elevated Relative Mortality and Morbidity Risks of Spouses and Other Family Members of Smokers Associated With Exposure to Environmental Tobacco Smoke. 3. Qualifications and Experience: Theodor D. Sterling and Associates Ltd. Work to prepare this submission to OSHA was supported by Phillip Morris U.S.A. However, the conclusions expressed in the comments are solely those of TDSA Ltd. and do not necessarily refl~Lthe views of Phillip Morris U.S.A. ~7C CJ't ~ 4eeodor a% se~11- a A iea. X W '~ ~'h G 00