Element Chromium,作为全球最大的铬(V1)化学品生产商，对OSHA提议的1pg/m³极低暴露限值提出质疑，认为现有数据不足以支持这一标准，并挑战其经济和技术可行性。他们呼吁重新审视规则制定中的经济和技术分析。讨论了工作场所空气污染物检测方法的进步，对OSHA现场访问数据的有效性提出疑问。
摘要：
Many of the concerns that Elementis Chromium has about this rule have been submitted to the docket for this rulemaking previously. This submission is intended to review some of the aspects that we do not believe that OSHA has properly considered and to respond to some of the issues raised by OSHA in the preamble of the proposed rule.Elementis Chromium is the only U.S. manufacturer of the basic hexavalent chromium chemicals, sodium dichromate and chromic acid. It also manufactures the largest volume of these chemicals worldwide. Consequently we believe that our experience in handling Cr(V1) chemicals is significant although, our industry has relatively few workers.These comments will consist of two parts. The first will be responses to selected issues proposed by OSHA in the preamble of the proposed rule. In the second part will be additional comments that we believe to be relevant to OSHA's consideration of this rule.We are especially concerned about the very low proposed PEL of 1 pg/m3. We do not believe that the available toxicological data or worker exposure experiencejustifies a value this low for the many industries and types of exposures covered by the rule. Also, we do not believe that this value is economically achievable by many facilities or technically achievable at the confidence level most facility managers expect. Recent advances in understanding of the effectiveness of various methods of sampling for air contaminants in the workplace will be discussed. This information raises significant doubt as to the usefulness of the exposure data obtained from the site visits conducted by OSHA and its contractors. Consequently, OSHA needs to completelyreexamine the economic and technical feasibility analyses performed for this rule.
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