This news is likely to have employers and safety professionals scrambling for information. With no recognized safe levels for surface contaminants like the permissible exposure limits for airborne hazards, or guidance for taking surface samples, many employers are likely to be at a loss. Only the most thorough chemical manufacturers, or work sites covered by Department of Housing and Urban Development rules on lead and EPA rules on PCB contamination, have surface monitoring programs in place, according to experts. Industrial hygienist Eric Botnick, director at Free-Col Laboratories in Meadeville, Pa., says his lab rarely comes across employers conducting wipe sampling for substances other than lead and PCBs. In four years Botnick can't remember processing more than four requests for surface sample analysis.
Some employers dismiss surface sampling on legal advice.
An OSHA source speaking not for attribution says he's heard that concern from employers before. It's a defense, but not an absolute one. To be sure, if OSHA begins its own surface sampling campaign, that defense will go out the window. Another argument against surface sampling is that it is an imprecise science. It's true that methods and results can vary depending on the surface being sampled, or the media used to collect the sample.